Item 5 Fees and Compensation
A.
INVESTMENT ADVISORY SERVICES
The Registrant provides discretionary and/or non-discretionary investment advisory
services on a fee basis. The Registrant’s annual investment advisory fee shall be based
upon a percentage (%) of the market value and type of assets placed under the Registrant’s
management, generally between negotiable and 1.00% as follows:
Assets Under Management Level Annual Fee
First $1,000,000 1.00%
Next $2,000,000 0.85%
Next $2,000,000 0.70%
Next $5,000,000 0.55%
Next $10,000,000 0.40%
Next $30,000,000 0.30%
$50,000,000+ Negotiable
The Registrant, in its sole discretion, may charge a lesser investment management fee based
upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional
assets, dollar amount of assets to be managed, related accounts, account composition,
negotiations with client, etc.). As a result, the Registrant’s clients could pay diverse fees
based upon the market value of their assets, the complexity of the engagement, and the
level and scope of the overall financial planning and/or consulting services to be rendered.
The services to be provided by the Registrant to any particular client could be available
from other advisers at lower fees. All clients and prospective clients should be guided
accordingly.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
The Registrant may be engaged to provide financial planning and/or consulting services
(including investment and non-investment related matters, including estate planning,
insurance planning, etc.) on a stand-alone fee basis. Registrant’s planning and consulting
fees are negotiable, but generally range up to $25,000 on a fixed fee basis, and from $250
to $500 on an hourly rate basis, depending upon the level and scope of the service(s)
required and the professional(s) rendering the service(s).
RETIREMENT PLAN SERVICES
The Registrant’s fee for providing non-discretionary pension consulting services is based
upon a percentage (%) of the market value of the assets within the plan and generally ranges
between negotiable and 0.75%. The terms and conditions of the engagement, including the
fee applicable to the engagement shall generally be set forth in a Retirement Plan Services
Agreement between the Registrant and the plan sponsor.
B. Clients may elect to have the Registrant’s advisory fees deducted from their custodial
account. Both Registrant's Investment Advisory Agreement and the custodial/clearing
agreement may authorize the custodian to debit the account for the amount of the
Registrant's investment advisory fee and to directly remit that management fee to the
Registrant in compliance with regulatory procedures. In the limited event that the
Registrant bills the client directly, payment is due upon receipt of the Registrant’s invoice.
C. As discussed below, unless the client directs otherwise or an individual client’s
circumstances require, the Registrant shall generally recommend that Charles Schwab &
Co., Inc. (“Schwab”) serve as the broker-dealer/custodian for client investment
management assets.
Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other
type fees for effecting certain types of securities transactions (i.e., including transaction
fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income
transactions, etc.). The types of securities for which transaction fees, commissions, and/or
other type fees (as well as the amount of those fees) shall differ depending upon the broker-
dealer/custodian. While certain custodians, including Schwab, generally (with the potential
exception for large orders) do not currently charge fees on individual equity transactions
(including ETFs), others do.
There can be no assurance that Schwab will not change their transaction fee pricing in the
future.
Schwab may also assess fees to clients who elect to receive trade confirmations and account
statements by regular mail rather than electronically.
Clients will incur, in addition to Registrant’s investment management fee, brokerage
commissions and/or transaction fees, and, relative to all mutual fund and exchange traded
fund purchases, charges imposed at the fund level (e.g., management fees and other fund
expenses).
D. Registrant’s annual investment advisory fee shall be prorated and paid monthly or
quarterly, in arrears, based upon the market value of the assets on the last business day of
the previous month or quarter. Billing adjustments are made on a pro rata basis for all
inflows and outflows during the billing period.
The Registrant utilizes Orion to calculate quarterly fees. Orion’s method for determining
account values differs from the method used by Schwab. As a result, the fees charged to
accounts maintained at Schwab may deviate slightly (higher or lower) than if the Registrant
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