ITEM 5 – FEES AND COMPENSATION
TCM charges a tiered, percentage-based fee, calculated on the market value of the assets in the client’s
account. Fees are paid in multiple ways; fees are payable quarterly in arrears and some are paid in advance.
Alternative frequency of payment and/or methods of calculation may be available, where appropriate or upon
a client’s request. The quarterly fee is calculated by multiplying the fair market value of cash and securities
in the portfolio as of the close of the quarter by the applicable quarterly percentage.
Accounts that open or close during the quarter will receive a prorated bill for the partial quarter. For those
clients that pay fees in advance, clients will receive a prorated refund of any unearned prepaid fees upon
termination. Client may terminate the investment advisory agreement at any time upon written notice
thereof to TCM. TCM may terminate the investment advisory agreement at any time upon thirty (30) day’s
prior written notice thereof to the client.
TCM’s management fees are ordinarily calculated by TCM and are calculated on TCMs valuation of the assets
in the client’s portfolio. In certain instances, TCM and the client may agree that the fees should be calculated
based upon the custodian’s valuation of the assets in the client’s portfolio. In addition, when TCM manages
multiple accounts for a particular client, or for a related group of clients, fee calculations may be based on the
total assets under management or a relationship fee discount may be available.
TCM obtains authorization from its clients to deduct management fees directly from the client’s account.
However, clients may direct TCM to bill for fees incurred. Where TCM has authorization to deduct the fees
from the account, TCM delivers an original invoice to the broker/custodian for payment and delivers a copy of
the invoice to the client.
In addition to TCM’s management fees, clients may incur brokerage, custodial and other transaction costs.
Please refer to Item 12 – Brokerage Practices for additional details.
FEE SCHEDULES – DUAL CONTRACT, SEPARATELY MANAGED ACCOUNTS
The following describes TCM’s standard fee schedules for separately managed accounts by platform and
product. Fees may be negotiable where special circumstances exist and arrangements with any particular
client may vary. Certain accounts of persons affiliated with TCM may be managed without fees or at a reduced
fee. In some cases, fees charged by TCM may be greater than fees charged by other investment advisers for
similar services, in other cases, our fees may be lower.
MULTI-CAP GROWTH
1.00% on the first $10mm, plus
0.50% on assets over $10mm
Minimum Account Size $1,000,000*
MULTI-CAP BALANCED
1.00% on the first $10mm, plus
0.50% on assets over $10mm
Minimum Account Size $1,000,000*
PARTNERS STRATEGY
1.00% on the first $10mm, plus
0.50% on assets over $10mm
Minimum Account Size $1,000,000*
SUSTAINABLE GROWTH
1.00% on the first $10mm, plus
0.50% on assets over $10mm
Minimum Account Size $1,000,000*
* TCM reserves the right to waive the minimum account size requirement.
FEE SCHEDULES – WRAP PROGRAMS, SEPARATELY MANAGED ACCOUNTS
Wrap program sponsors typically offer comprehensive brokerage, custodial and advisory services for a single
“wrap fee” based on a percentage of assets under management. The program sponsor then pays TCM a portion
of the wrap fee in connection with the advisory services it provides. In wrap fee accounts, TCM is chosen by
the client to act as an investment adviser through a selection process administered by the wrap program
sponsor. The client information compiled through the selection process enables TCM to provide individualized
investment services, which it maintains through ongoing contact with the wrap sponsor. TCM is available for
direct telephone calls with wrap clients at their request, and periodically, at the discretion of the wrap sponsor.
The wrap sponsor’s services generally include, in addition to assistance with the selection of one or more
investment advisers, execution of portfolio transactions (free of commissions), custodial services, including
trade confirmation and periodic reporting, continuing evaluation of investment performance, and consultation
on investment objectives and suitability.
When TCM serves as a wrap investment sub-adviser, it contracts with the wrap program sponsor for its
services rather than the clients of the wrap sponsor. The wrap sponsor serves as a master investment adviser
and is responsible for much of the client record-keeping and reporting. The management fees payable to TCM
are generally lower than those paid to TCM as a dual contract separate account manager, reflecting that some
of the services it would otherwise provide are provided instead by the program sponsor.
Each client should evaluate whether a given wrap program is suitable for their needs. The client should
consider the level of the single fee being charged under the wrap program relative to the package of services
being provided including the amount of portfolio activity in the account as well as the value of custodial and
portfolio monitoring services. The single fee may be higher or lower than the total cost of all services the client
is receiving were they to pay for each service separately.
The following describes TCM’s standard fee schedules for WRAP platforms by product. Fees and minimums
may be negotiable where special circumstances exist and arrangements with any particular client may vary.
MULTI-CAP GROWTH EQUITY
0.50% on all assets
Minimum Account Size: $1,000,000
FEE SCHEDULES – MUTUAL FUNDS
TCM provides investment management services as an adviser to the “Cromwell Tran Sustainable Focus Fund
– Total Funds Solutions” (Cromwell Tran Sustainable Focus Fund) and the “Cromwell Sustainable Balanced
Fund”, portfolios registered under the Investment Company Act of 1940. TCM charges the Cromwell Tran
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