ITEM 5 ‐ FEES AND COMPENSATION
In its capacity as a registered investment adviser, Winslow’s principal source of income
is the advisory fees charged on advisory accounts. Winslow also derives revenue from
commissions and other fees paid on transactions and from third party sources. The
fees, charges and expenses are set forth below.
A. Advisory Fees
1. MAP I
The advisory fee for MAP I is between 0.50% and 2.50% of assets under management.
Fees are negotiable within the aforementioned limits. Fees cover investment
management services and account administration only. If applicable, an account will
be charged separately for custody, clearing services, and certain administrative costs
(e.g., postage and handling). Please see paragraph C (2) of this section and Addendums
1-6 for more details.
2. MAP II
Winslow’s advisory fee for MAP II is between .70% and 1.75% of assets under
management. Fees are negotiable within the aforementioned limits. Fees cover
investment management services and account administration only. If applicable, an
account will be charged separately for custody, clearing services and certain
administrative costs (e.g., postage and handling). Those fees depend in part upon
which clearing firm custodies your assets. Please see paragraph C (2) of this section
and Addendums 1 – 6 for additional fee details by custodian.
Please note that, for accounts invested in the Sawtooth Program, there is an additional
investment manager fee to compensate the independent investment manager for
money management services, i.e., selecting the actual securities that populate the
account portfolio. The account is charged for the investment manager fee. Sawtooth
also has a separate platform fee of .25% of assets under management. Winslow pays
that expense directly and does not charge the client account for that expense.
In addition, clients will be responsible to SEI for any fees and expenses in connection
with ownership and transactions in the SEI mutual funds. These include the expense
ratios charged by each mutual fund and may include redemption fees. You may also be
charged so-called 12b-1 mutual fund distribution fees and, depending on your
custodian, those fees may or may not be automatically credited back to your account
by that custodian.
If your assets are custodied at Raymond James, Fidelity, TD Ameritrade or SEI,
Winslow, itself, does not receive any 12b-1 fees. With respect to assets custodied at
Pershing, Winslow has, effective May 2019, instructed Pershing to credit all 12b-1 fees
back to your account.
With respect to money market mutual fund assets custodied at Pershing, Winslow has
a Cash Sweep Program in place. Under that Program, clients may select from among
the available money market options in Pershing’s Cash Management ChoiceMoney
Market Funds program. Clients who wish to designate a specific money marketfund
may identify that fund in their account opening documents and/or instruct their IAR
to review the requested fund and use it (if available). In the event that a client does not
request a specific fund, Winslow moves money marketassets into a Pershing money
market product that does not pay distribution assistance (revenue sharing) to
Winslow.
For account positions opened prior to September 30, 2019, Winslow had been
defaulting customers into sweep funds from which Pershing paid Winslow
distribution assistance. However, effective September 30, 2019, Winslow instructed
Pershing to move those positions into funds that do not pay distribution assistance.
Please see the relevant Pershing and SEImutual fund prospectuses as well as Items
5.C.3 and 12.A.6 of this Brochure for furtherdetails.
Finally, prior to October 31, 2020, Winslow had been receiving revenue sharing
payments on certain FundVest NTF mutual fund positions held at Pershing. Effective
October 31, 2020, Winslow instructed Pershing to refund any further payments made
under that program and Winslow instituted policies and procedures to confirm such
refunds.
3. MAP III
You will pay a Wrap Fee for the service, which includes the investment advisory fee
that the investment manager receives as well as all execution costs, ticket charges, SEC
fees and other administrative costs. The Wrap Fee charged in the MAP III program is
1% to 2% of the assets in the account including cash and cash equivalents. Fees are
negotiable.
4. MAP IV
You will pay a Wrap Fee for the service, which includes the investment advisory fee
that the investment manager receives as well as all execution costs, ticket charges, SEC
fees and some administrative costs. The Wrap Fee charged in the MAP IV program is
1% to 2% of the assets in the account including cash and cash equivalents. Fees are
negotiable.
5. WSF
WSF accounts carry an advisory fee ranging from 1.50% to 1.75% for accounts under
$100,000 and 0.75% to 1% for accounts over $1 million. Fees are negotiable within the
WSF Program limits. Fees cover investment management services and account
administration only.
As described above, the WSF program utilizes NTF funds offered by Pershing and
Raymond James (two of Winslow’s clearing firms). NTF funds carry no execution
related charges. They may, however, carry certain mutual fund revenue sharing costs
and 12b-1 fees, If your assets are custodied at Raymond James, Fidelity, TD
Ameritrade or SEI, Winslow, itself, does not receive any 12b-1 fees or revenue
sharing. With respect to assets custodied at Pershing, Winslow has, effective May
2019, instructed Pershing to credit all 12b-1 fees back to your account and, effective
October 31, 2020, instructed Pershing to credit back all revenue sharing payments
In the event that your account holds securities other than NTF funds, you will be
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