Item 5 ‐ Fees and Compensation
Investment Advisory and Management Services
Our fees are negotiable and may vary based on the particular circumstances of each client. In addition,
certain affiliated persons and family members and personal acquaintances of affiliated persons may receive
advisory services from us at a discounted rate which is not available to advisory clients generally. Clients are
requested to authorize in writing deduction of fees due and payable to SGWM directly from such client’s
account managed by SGWM.
SGWM is compensated for its services primarily by charging a percentage of the value of its clients’ assets
under management (“AUM”). The specific manner in which SGWM charges its fees is tailored to the services
that SGWM has agreed to provide to a client and is established in each client’s written agreement with
SGWM. In accordance with each client’s individual investment objective, SGWM provides investment
advisory services on both a discretionary and non‐discretionary basis to high‐net‐worth individuals and
institutions and recommends a selection of various investment products, such as fixed income and
equities, options, financial planning and services through its investment adviser representatives,
financial planners and portfolio managers and through third parties
SGWM charges an annual management fee equal to a percentage of the market value of all of the client’s
assets under management as follows:
Equity/Balanced and Fixed Income Accounts
Fee Assets Under Management (“AUM”)
1.5% On the first $500,000
1.25 On the next $500,000
1% On the next $1MM
Negotiable On AUM above $2 million
If SGWM charges its annual management fee monthly, the annual fee percentage is divided by 12 to arrive at
the monthly fee. If SGWM charges its annual management fee quarterly, the annual fee percentage is divided
by four to arrive at the quarterly fee. Fees for managed accounts are negotiable on a case‐by‐case basis.
Accounts with special investment guidelines will be charged differently based on the nature and complexity
of the services rendered, portfolio holdings and other factors. Fees for investment advisory services with
respect to options and other related investments will vary depending on the individual needs and the size of
the account. SGWM may in special circumstances negotiate its management fees for large institutional
accounts, retail accounts or other accounts in special circumstances, thereby resulting in lower management
fees and fees that may be billed annually instead of monthly or quarterly. SGWM may make exceptions to
annual management fee minimums or minimum account size based on the specific circumstance of an
account.
Management fees are charged monthly or quarterly on a negotiated basis and are generally billed at the
beginning of a calendar month or quarter (a “billing period”). Management fees for services initiated during
the initial billing period will be charged at the end of the initial billing period and will be prorated for terms
less than a full billing period. Thereafter management fees will be charged at the beginning of the billing
period. Fees may be charged at the end of the billing period in other circumstances, as set forth in the client’s
written agreement.
Some accounts may be under different fee schedules honoring prior agreements. Our standard fee schedule may be
negotiable based on a number of factors which include, but are not limited to “grandfathered” accounts, account size,
related accounts, accounts referred to us from an unaffiliated broker‐dealer, and other structures that we may consider
in special situations. We may determine to charge a fee that is higher than the amount referenced above, especially
when the client and their previous adviser transitioned from another investment adviser where they were paying a
higher fee. Cash balances and balances subject to currently outstanding margin loans will be included for fee
calculation purposes. SGWM may aggregate client accounts that have family relationships with each other for
purposes of calculating the advisory fee rate applicable to each client. We also manage some family and related
accounts without charge.
Wrap Fee Program Services
The current annual Program Fee is capped at 1.5% and is based on the amount of assets placed under SGWM’s
management. The Program Fee is negotiable and subject to change. Each client’s Program Fee is set forth in
a written agreement between SGWM and the client. Wrap Fee Program Service fees are described more fully
in the Part 2A Appendix.
Financial Planning & Consulting
In the event that SGWM provides advisory services other than portfolio management on a discretionary basis,
SGWM may charge hourly fees or fixed fees for those services. The specific manner in which SGWM charges
its fees is tailored to the services that SGWM has agreed to provide to a client and is established in each client’s
written agreement with SGWM. Fees for financial planning services are negotiable and may be fixed, hourly
or flat. If a client requests or arranges to have a customized report or analysis prepared (for example, analysis
of group benefit programs or a qualified retirement plan design), fees for such planning or development of an
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