ITEM 5. FEES AND COMPENSATION
A. Compensation for Advisory Services - Asset-Based Fees for Portfolio Management and Investment
Advisory Services
Total Assets Under Management Annual Fee
$0 - $249,999 2.25%
$250,000 - $499,999 2.00%
$500,000 - $999,999 1.75%
$1,000,000 - $4,999,999 1.50%
$5,000,000 - $9,999,999 1.25%
$10,000,000 - And Up 1.00%
These fees are generally negotiable, and the final fee schedule is attached as Exhibit II of the
Investment Advisory Contract. Clients may terminate the agreement without penalty for a full
refund of TFPL's fees within five business days of signing the Investment Advisory Contract.
Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days'
written notice.
B. Payment of Asset-Based Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts with
client's written authorization monthly or may be invoiced and billed directly to the client monthly.
Clients may select the method in which they are billed. Fees are paid in advance.
C. Client Responsibility for Third Party Fees
TFPL may wrap third party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction
fees, etc.). TFPL will charge clients one fee and pay all transaction fees using the fee collected from
the client.
D. Prepayment of Fees
TFPL collects fees in advance. Refunds for fees paid in advance will be returned within fourteen
days to the client via check or return deposit back into the client’s account.
For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees
collected in advance minus the daily rate* times the number of days elapsed in the billing period
up to and including the day of termination. (*The daily rate is calculated by dividing the annual
asset-based fee rate by 365.)
E. Outside Compensation for the Sale of Securities to Clients
TFPL or its supervised persons may accept compensation for the sale of securities or other
investment products, including asset-based sales charges or services fees from the sale of mutual
funds.
Cynthia Denise DiBartolo, Ivan Philip Feinseth, Lily Li and Diego Arancibia are registered
representatives of TFPL, a FINRA member broker-dealer.
1. This is a Conflict of Interest
Supervised persons may accept compensation for the sale of securities or other investment
products, including asset-based sales charges or service fees from the sale of mutual funds to
TFPL's clients. This presents a conflict of interest and gives the supervised person an incentive to
recommend products based on the compensation received rather than on the client’s needs. When
recommending the sale of securities or investment products for which the supervised persons
receives compensation, TFPL will document the conflict of interest in the client file and inform the
client of the conflict of interest.
2. Clients Have the Option to Purchase Recommended Products from Other
Brokers
Clients always have the option to purchase TFPL recommended products through other brokers or
agents that are not affiliated with TFPL.
3. Commissions are not TFPL's primary source of compensation for advisory
services
Commissions are not TFPL’s primary source of compensation for advisory services.
4. Advisory Fees in Addition to Commissions or Markups
Advisory fees that are charged to clients are not reduced to offset the commissions or markups on
securities or investment products recommended to clients.