Item 5 - Fees And Compensation
A. Advisory Fees
Investment Management Services
Advisory fees for Investment Management Services are agreed upon at the time of
engagement and are stipulated in the client Advisory Agreement.
Fees are charged quarterly in advance, unless otherwise agreed upon by the client, and are
based upon the market value of the portfolio, set forth by the custodian, as of the last market
day of the relevant calendar period (unless otherwise agreed upon by the client). Where
services are initiated at any time other than the beginning of the calendar quarter, advisory
fees shall be prorated. Advisory fees are as follows:
Portfolio Value Maximum Annual Fee (%)
First $2 million 1.00%
Next $3 million 0.85%
Next $5 million 0.70%
Balance above $10 million Negotiable
Steward Capital Management, Inc.
Effective Date: March 28, 2025
The advisory fee schedule and account size may be modified due to a variety of factors at the
sole discretion SCM. Payment of advisory fees will be agreed upon in the Advisory
Agreement by all parties.
Investment Advisory Services
Fees for Investment Advisory Services are typically charged as a fixed fee and are agreed
upon at the time of engagement and stipulated in the client Advisory Agreement.
B. Payment Method
There are two options a client may select to pay SCM’s advisory services fees:
Direct Debiting
Each quarter, SCM will notify the client’s qualified custodian of the amount of the fee due
and payable to SCM pursuant to the firm’s fee schedule and advisory agreement. The
qualified custodian will not validate or check SCM’s fees, its corresponding calculation or the
assets on which the fee is based unless the client has retained their services to do so. With
the client’s pre-approval, the qualified custodian will “deduct” the fee from the client’s
account or, if the client has more than one account, from the account the client has
designated to pay SCM’s advisory fees.
Each month, the client will receive a statement directly from the qualified custodian showing
all transactions, positions and credits/debits into or from the client’s account. Statements
sent after quarter end will also reflect the advisory fee paid by the client to SCM.
Billing
Each quarter, SCM will issue the client an invoice for the firm’s services and the client will
pay SCM by check or wire transfer. All invoices are due upon receipt.
C. Additional Fees and Expenses
Mutual Fund Fees and Exchange Traded Funds
All fees paid to SCM for investment advisory services are separate and distinct from the fees
and expenses charged by mutual funds and exchange-traded funds (“ETFs”) to their
shareholders. These fees and expenses are described in each fund's or ETF’s prospectus.
These fees will generally include a management fee, other fund expenses, and a possible
distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred
sales charge. A client could invest in a mutual fund or ETF directly, without the services of
SCM. In that case, the client would not receive the services provided by SCM which are
designed, among other things, to assist the client in determining which mutual fund or ETF
is most appropriate to each client's financial condition and objectives.
To the extent that client assets are invested in money market funds or cash positions, the
fees for monitoring those assets are in addition to the fees included in the internal expenses
of those funds paid to their own investment managers, which are fully disclosed in each
fund’s prospectus. Accordingly, the client should review both the fees charged by the funds
and the fees charged by SCM to fully understand the total amount of fees to be paid by the
client and to thereby evaluate the advisory services being provided.
Steward Capital Management, Inc.
Effective Date: March 28, 2025
Trading and Other Costs
All fees paid to SCM for investment advisory services are separate and distinct from
transaction fees charged by broker dealers associated with the purchase and sale of equity
securities and fixed-income securities. In addition, fees do not include the services of any co-
fiduciaries, accountants, broker dealers or attorneys. Please see the “Brokerage Practices”
section of this disclosure brochure for additional information on brokerage and other
transaction costs.
D. Termination and Refunds
A client agreement may be canceled at any time, by either party, for any reason upon receipt
of written notice. Termination shall be effective immediately upon receipt of notice by the
other party. Since fees are billed quarterly in advance, SCM will refund to the client a pro-
rata share of the fees paid computed on a daily basis for the 90-day quarter.
A client’s death shall not terminate the advisory agreement or the authority granted to SCM
until SCM has received actual written notification of the client’s death.
E. Additional Compensation
SCM is compensated solely by fees paid by its clients and does not accept commissions or
compensation from any other source (i.e., mutual funds, insurance products or any other
investment product).
F. Additional Information
Fees Negotiable
SCM retains the right to modify its fee schedule in its sole and absolute discretion, on a
client-by-client basis based on the size, complexity and nature of the advisory services
provided. All fees will be agreed upon in writing by the client prior to being charged.
Private Investment Funds
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