Twele Capital Management Inc

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Twele Capital Management Inc
CRD #130239
SEC #801-67477
CIK #0001411268
AUM 578.5 M (2026-01-06)
Employees 4 (75% Investors, 0% Brokers)
Fees
Minimum
Phone952-887-9253
Address5601 Smetana Drive
Minnetonka, MN 55343-9196
Source [IAPD] [EDGAR] [Website] [LinkedIn]
Total AUM ($M)
90072054036018002005201220192027
Fees and Compensation — Form ADV Part 2A (1/6/2026) [Brochure]
Item 5 Fees and Compensation
The annualized fee charged to individual clients for our services, calculated as a percentage of
assets under management, is as follows:

          Assets Under Management               Annual Fee
          Below $5.0 Million                    0.65%
          Above $5.0 Million                    0.50%

Institutional client fees, also calculated as a percentage of assets under management, are
negotiable based on size and scope.

Fees are calculated in arrears at the end of each quarter based upon the amount of assets under
management. Fee amounts are adjusted for cash flows (contributions and withdrawals) during
the period. Fees are deducted from client assets at the end of each calendar quarter.

Limited Negotiability of Individual Client Advisory Fees:
Although Twele Capital has established the aforementioned fee schedule; we retain the
discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and
needs will be considered in determining the fee schedule. These include the complexity of the
client, assets to be placed under management, anticipated future additional assets, related
accounts, account composition, reporting requirements, among other factors. The specific fee
schedule will be identified in the contract between Twele Capital and each client.

Discounts can be offered to family members and friends of associated persons of our firm.

GENERAL INFORMATION

Termination of the Advisory Relationship:
A client agreement can be canceled at any time, by either party, for any reason upon receipt of
written notice. As disclosed above, no fees are paid in advance of services provided. Upon
termination of any account, any owed fees will be calculated and due as of the date of
termination. In calculating a client’s accrued, but unpaid fees, we will pro rate the fees according
to the number of days since the last billing period.

Exchange-Traded Funds (ETFs) Fees:
All fees paid to Twele Capital for investment advisory services are separate and distinct from the
fees and expenses charged by ETFs to their shareholders, also known as "expense ratios". These
fees and expenses are described in each fund's prospectus. These fees will generally include a
management fee and other fund expenses. Accordingly, the client should review both the fees
charged by the funds and our fees to fully understand the total amount of fees to be paid by the
client and to thereby evaluate the advisory services being provided.

Additional Fees and Expenses:
In addition to our advisory fees, clients are also responsible for the fees and expenses charged
by custodians and imposed by broker dealers, including, but not limited to, any transaction
charges imposed by a broker dealer with which Twele Capital effects transactions for the client's
accounts. Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for
additional information. Examples of other potential fees that clients are responsible for include,
but are not limited to, wire fees for moving cash to external bank accounts or express mailing
fees.

Minimum Account Requirements:
Generally, a minimum of $500,000 of assets under management is required for this service. This
account size is negotiable. Twele Capital will group certain related client accounts for the
purposes of achieving the minimum account size and determining the annualized fee.

ERISA Accounts:
Twele Capital is deemed to be a fiduciary to advisory clients that are employee benefit plans or
individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and
Securities Act (“ERISA”), and regulations under the Internal Revenue Code of 1986 (the "Code"),
respectively. As such, our firm is subject to specific duties and obligations under ERISA and the
Internal Revenue Code that include among other things, restrictions concerning certain forms of
compensation. As a fee-only investment manager, Twele Capital does not receive 12b-1 fees or
commissions of any kind.

Advisory Fees in General:
Clients should note that similar advisory services may (or may not) be available from other
registered (or unregistered) investment advisers for similar or lower fees. Under no circumstances
do we require or solicit payment of fees in advance of services rendered.

Other Fees:
From time to time, client-specific circumstances, including but not limited to, divorce,
distributions of estate assets, cost-basis research and administrative support to client attorneys
and accountants will be subject to hourly charges. The hourly fees will range from $200 - $500
depending on the circumstances. In no case will charges be levied without prior notification and
written approval by the client.
Account Minimums and Types of Clients — Form ADV Part 2A (1/6/2026) [Brochure]
Item 7 Types of Clients
Twele Capital provides advisory services to the following types of clients:

   •   Individuals (other than high net worth individuals)
   •   High net worth individuals
   •   Pension and profit-sharing plans
   •   Trusts and charitable organizations
   •   Corporations
AUM Breakdown Accounts AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals) 30 16.2
(b) Individuals (high net worth individuals) 37 95.6
(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 0 456.8
(h) Charitable organizations 0 2.1
(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 0 6.8
(n) Other 0 1.1
Total 201 578.5
By Discretionary
Discretionary 201 578.5
Non-Discretionary 0 0.0
Total 201 578.5
By Non-United States Persons
Non-United States Persons 1.4
United States Persons 577.1
Total 201 578.5
EDGAR Form CIK 2011 - 2026
13F-HR [0001411268]
Firm Profile (Form ADV)
Discretionary AUM$0.4B
ServesInstitutional, Retail
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