ITEM 5: FEES, COMPENSATION AND TERMINATION OF SERVICES
A. Description of Compensation and Fee Schedule
Valor Capital’s investment management advisory fee and/or TAMP platform fee consists of an
annual fee based on assets under management, or agreed upon rate, billed monthly in advance,
based on the average daily account balance of the prior month. Accounts opened in mid-month are
assessed a pro-rated management fee. Fees for the initial month are adjusted pro-rata based upon
the number of calendar days in the calendar month that the account is invested in a billable strategy.
The following is the Firm’s fee schedule for investment management and other platform services
such as account opening, billing, reporting, and trading:
Asset Level: Maximum Fee:
$0 - $499,999 60 bps
$500,000 - $999,999 50 bps
$1,000,000 - $1,999,999 40 bps
$2,000,000 - $4,999,999 35 bps
$5,000,000+ 30 bps
Valor may charge a $150.00 minimum annual investment management fee which may result in a
fee greater than the fees stated above. Valor’s fees may be less than the maximum fees outlined
above. Certain Separate Advisor Clients with pre-existing relationships may initially be charged
fees which are less than those set out above. With regard to employee-related accounts and certain
other accounts, the fees may be less, depending upon a number of factors, including portfolio size,
length of employment, and relationship to the employee. Fees are subject to change with thirty
(30) days written notice.
Valor maintains a Limited Power of Attorney for all the model portfolios and strategies for the
purposes of directing and/or otherwise effecting investments on behalf of the managed accounts
invested in the portfolios and for the payment of the advisory fees charged by the Firm and the
Separate Advisor, custodial fees and/or other charges incurred by the managed account.
Fund Strategist fees are negotiated with the Platform Provider and may be as high as an annual
rate of .40% of assets under management. Separate Advisor Clients typically pay additional
management fees above and beyond Valor’s fee for which Valor has no control over nor receives
any benefit from.
Clients should be aware that Valor’s advisory fee and/or platform fee can be higher or lower than
those charged by others in the industry, and that it can be possible to obtain the same or similar
services from other investment advisers at lower or higher rates.
B. Payment of Fees
Fees are payable monthly, in advance, based on the average daily account balance of the prior
month. Such fees will be deducted from the Client's account(s) following the end of the month.
Incoming new accounts are charged the month after funding and prorated to the end of the month.
Payment of advisory fees of a de minimis nature can be waived at Valor Capital’s discretion.
Fund Strategist advisory fees are paid to Valor by the Platform Provider as agreed upon via the
agreement entered into by Valor and the Platform Provider. SMA providers may deduct their fees
from the client account as outlined above.
C. Other Fees
Unmanaged Assets
As a service and convenience for Separate Advisor’s and their Clients, Valor may hold
unmanaged assets separately from managed assets in the Client’s account. Valor does not
provide any investment advisory services with respect to unmanaged assets. The administrative
fee for this service is $150/year billed on a pro rata basis, monthly, in advance. Valor’s
administrative fee is in addition to fees charged by the custodian to hold the assets within the
account(s). Valor can choose to waive this fee at its discretion.
Separately Managed Accounts & Other Programs
Valor charges clients a tiered asset-based program fee based on assets invested with the firm in
addition to the fee that is charged by your advisor and the SMA manager fee and/or other
program manager fee, as applicable. The Firm’s fee schedule is outlined above. All fees will be
disclosed to through the Valor Schedule A or through a similar document provided by the RIA
you work with.
Custodial Services
Separate Advisors and Clients may select and utilize the custodial, brokerage and clearing
services of multiple broker-dealers, including, but not limited to, TD Ameritrade Institutional,
a division of TD Ameritrade, Inc. (“TD Ameritrade”), Charles Schwab, and Fidelity
Investments Institutional Brokerage Group (“Fidelity”). These broker-dealers offer services to
Separate Advisors which include custody of securities, trade execution, clearance, and
settlement of transactions. The broker-dealer fees and costs vary and can be higher or lower
depending on the firm selected by the Separate Advisor and Client. The fees charged by Valor
are in addition to the fees charged by any Separate Advisor utilizing the services of Valor and
any charges assessed by the Client’s Custodian providing brokerage and clearing services.
Custodial fees could include, but are not limited to, transaction fees, short term redemption fees,
account transfer fees and/or account closing fees. These fees are charged by the custodian, and
not paid to Valor Capital Management. Check with your custodian for further details about their
charges.
Underlying Investment Fees
To the extent mutual funds or ETFs are selected to fill components of the overall investment
strategy, the annual advisory fee set forth above does not include the customary fees and
expenses associated with investing in mutual funds and ETFs or other costs of establishing and
maintaining an account with mutual funds and ETFs such as the fund’s management fee or
distribution fee, typically called Rule 12b-1 fees. These fees and expenses are described in each
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