ITEM 5: FEES AND COMPENSATION
A. Description and Billing
SC earns its fees and compensation by providing advice and investment management
services to clients. The compensation will be in the form of Management fees (the
“Management Fee”). SC deducts its fees automatically from each client’s account balance
pursuant to the fee structure agreement upon and between the client and SC. The fees you pay
us do not include brokerage commissions or other fees or charges associated with securities
transactions implemented with or through a brokerage firm, mark-ups or mark-downs in
principal transactions, deferred sales charges, stock exchange fees, wire transfer or related
processing fees, transfer taxes or other charges mandated by law or regulation all of which will
be charged to you in addition to our fee. We do not receive any portion of any of the foregoing
expenses or fees. You should go to the section on Brokerage Practices in our brochure for more
information on how we select or recommend brokerage firms for your securities transactions
and information related to that process.
You should understand that mutual funds, including exchange traded funds, in which your
assets are invested by us or by others, impose separate investment management fees and other
operating expenses, described in the fund’s prospectus, for which you, the client, will be
charged separately from the fee paid to us for our services. Clients may pay their fees directly
if they wish to do so. Our compensation and billing procedures are as follows:
1. Management Fees
A Management Fee is paid quarterly in advance to SC based on the account’s value on the
first day of each quarter. The following maximum fee schedule shall be applied to client
assets under management on the first day of each quarter.
Assets between $0 and $1,000,000: 1.50% (0.375% quarterly)
Assets between $1,000,001 and $5,000,000: 1.0% (0.25% quarterly)
Assets between $5,000,001 and $10,000,000: 0.75% (0.1875 quarterly)
Assets between $10,000,001 and $25,000,000: 0.50% (0.125% quarterly)
Assets over $25,000,001: 0.25% (0.0625% quarterly)
SC may waive or negotiate a lower fee with any client.
B. Refund Policy
Our Management Fee is assessed in advance and billed at the start of each quarter. A client
relationship may be severed at any time, by either party, for any reason upon receipt of 30
days’ written notice. Upon termination of any account, any prepaid, unearned fees will be
promptly refunded. In calculating a client’s reimbursement of fees, we will pro rate the
reimbursement according to the number of days remaining in the billing period.
C. Other Compensation
SC does not accept any compensation other than Management Fee.