Item 5 – Fees and Compensation
Portfolio Management Fees
Wellington provides discretionary investment management services to clients and charges annual
fees, payable quarterly either in advance or in arrears (depending on the terms of each investment
management agreement).
We charge up to a 2.00% fee on all assets, subject to negotiation. When charged in advance, fees
are calculated on the total market value of each account (including on assets invested in cash and
cash equivalents and on accrued interest and dividends) on the last day of the prior quarter except
as otherwise described in this section. Unless an alternative method is agreed upon in writing,
asset-based portfolio management fees are withdrawn directly from your account(s) on a quarterly
basis.
The fee schedule is typically a tiered schedule of fees, but a flat fee percentage or dollar amount
may be negotiated. All fee schedules will be documented in the client’s written advisory
agreement.
When charged in arrears, fees are calculated on the total market value of each account (including
on assets invested in cash and cash equivalents and on accrued interest and dividends) on the last
day of the month or quarter, except as otherwise described in this section.
Clients may terminate their Wellington agreement without penalty for a full refund of fees within
five business days of signing their advisory agreement. Thereafter, clients may terminate the
agreement pursuant to the termination clause in their agreement. Any unearned fees will be
refunded to the client based on the number of days under management.
As discussed in Item 6, we do not charge performance-based fees.
Fees for the Selection of Other Advisers
When Wellington recommends that a client engage a third-party investment adviser or sub-
manager, Wellington may receive a portion of the advisory fee charged by that third-party adviser or
program sponsor. This compensation arrangement will be disclosed to the client and memorialized
in the applicable agreements. The timing, frequency, and method of payment will depend on the
specific third-party adviser, program, or investment arrangement selected.
In some cases, the client will pay a single bundled advisory fee that is shared between Wellington
and the third-party manager. In other cases, the client may pay Wellington’s advisory fee
separately and also bear the fees and expenses of the third-party manager, strategy sponsor, fund,
or program. Clients should review all applicable agreements, offering documents, and account
paperwork carefully to understand the total fees and expenses associated with the
recommendation.
Financial Planning Fees
TWG Firm Brochure V1 - 2026
Financial planning fees can be paid via check to Wellington or can be invoiced and processed
through a third-party nonaffiliated service, AdvicePay. With AdvicePay, Clients will be asked to set
up their bank account or credit card at AdvicePay to enable credit card or ACH payments. While
AdvicePay allows firms like Wellington to receive payments directly from the client’s credit card or
bank account, it does not give Wellington access to the bank account itself, nor to any of the
client’s credit card or bank account information. Wellington is not able to initiate any additional
payments via AdvicePay as agreed upon and outlined in the Agreement. Fixed financial planning
fees are paid 50% in advance, but never more than six months in advance, with the remainder due
upon presentation of the plan.
As part of our initial engagement, clients will generally be required to pay a financial planning fee
between $250 and $10,000. This fee is negotiable and nonrefundable and covers general financial
planning and the front-end administrative work necessary to bring you on as a client of the firm. In
subsequent appointments, we will begin more thoroughly developing your financial and investment
plans to provide comprehensive and dynamic guidance. The initial fee does not cover creation of a
comprehensive financial plan but the time and effort that goes into collecting and organizing all the
necessary documentation/paperwork necessary during the new client on-boarding and application
process.
After signing your investment advisory agreement, we will provide ongoing financial planning
services under the terms of that agreement. We do not require the completion of a formal financial
planning agreement. We will use the information gathered during the initial engagement to begin
reviewing and prioritizing your goals and objectives in a more comprehensive capacity. The review
of your current investment portfolio and the development of an asset management strategy, the
completion of a retirement planning assessment, including financial projections of assets required
at estimated retirement date, and the development of any action plan to implement the agreed
upon recommendations. At any point during our relationship, you can disengage from our services
without additional penalties or costs beyond what has already been paid.
For estate planning services provided through third-party platforms such as Wealth.com, our firm
may collect fees from clients to cover the cost of document creation. These fees will be clearly
disclosed in writing and are separate from our advisory fees. We do not receive commissions or
compensation from these third-party providers.
Clients are under no obligation to use any estate planning platform recommended or made
available by our firm.
Valuation
Your custodian, typically Charles Schwab, is responsible for valuing all assets in your account.
Valuation is not the responsibility of Wellington. Securities without a readily available market price
shall be valued as determined in good faith by the custodian, as appropriate, to reflect their fair
value. Wellington, Platform providers and Sub-Managers will cooperate with custodian in
custodian’s good faith efforts to determine fair market value. Regarding client account assets in
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