Fees and Compensation — Form ADV Part 2A (3/29/2025)
[Brochure]
“Item 5: Fees and Compensation.” You will also receive quarterly statements directly from custodian of
the account that details all transactions in the account. You should carefully review those statements
promptly when you receive them. We also urge you to compare TD Ameritrade’s account statements to
the periodic portfolio reports you will receive from us.
For accounts where the client has a standing letter of authorization that allows us to transfer money
between accounts specified by the client, we are also deemed to have custody. We follow the guidance
outlined in the Investment Adviser Association no-action letter dated February 21, 2017, for these
accounts. A copy of this letter is available upon request.
At no time do we accept physical custody of client assets.
Account Minimums and Types of Clients — Form ADV Part 2A (3/29/2025)
[Brochure]
ITEM 7: TYPES OF CLIENTS
Our clients are all individual investors and most would typically be considered high-net worth
individuals. The vast majority of our clients are retired. These individuals will typically have a trust
account, joint account or individual account, in addition to a retirement account (IRA Rollover, Roth IRA,
Traditional IRA, Individual 401k or Defined Benefit Plan). In addition, we also manage custodial
accounts on behalf of clients.
Generally we require that you maintain $1,000,000 under management with us. However, we may waive
that minimum at our sole discretion.
AUM Breakdown
Accounts
AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals)
100
72.3
(b) Individuals (high net worth individuals)
70
335.5
(c) Banking or thrift institutions
0
0.0
(d) Investment companies
0
0.0
(e) Business development companies
0
0.0
(f) Pooled investment vehicles
0
0.0
(g) Pension and profit sharing plans
0
0.0
(h) Charitable organizations
0
0.0
(i) State or municipal government entities
0
0.0
(j) Other investment advisers
0
0.0
(k) Insurance companies
0
0.0
(l) Sovereign wealth funds and foreign official institutions
0
0.0
(m) Corporations or other businesses not listed above