We offer wrap fee programs as described in this Wrap Fee Program Brochure. Our wrap fee accounts
are managed on an individualized basis according to the client’s investment objectives, financial
goals, risk tolerance, etc.
A wrap fee program allows our clients to pay a specified fee for investment advisory services and the
execution of transactions. The advisory services may include portfolio management, and the fee is
not based directly upon transactions in your account. Your fee is bundled with our costs for executing
transactions in your account(s). This results in a higher advisory fee to you. We do not charge our
clients higher advisory fees based on their trading activity, but you should be aware that we may
have an incentive to limit our trading activities in your account(s) because we are charged for
executed trades. By participating in a wrap fee program, you may end up paying more or less than
you would through a non-wrap fee program where a lower advisory fee is charged, but trade
execution costs are passed directly through to you by the executing broker.
LPL Financial offers a trading platform with select exchange traded funds (“ETFs”) that do not charge
transaction fees. The no-transaction-fee ETF trading platform is available to clients participating in
LPL Financial’s Strategic Wealth Management (“SWM”) and Strategic Asset Management (“SAM”)
programs. Since our firm pays the transaction fees charged by LPL Financial to clients participating
in our wrap fee program, we are incentivized to recommend no-transaction-fee ETFs over other
types of securities and ETFs in order to reduce our costs. This presents a conflict of interest because
the limited number of ETFs available on the no-transaction fee platform may have higher overall
expenses than other types of securities and ETFs not included in the platform. In addition, other
major custodians have eliminated transaction fees for all ETFs and U.S. equities, so clients may pay
more for investing in the same securities at LPL Financial.
Charles Schwab & Co., Inc. (“Schwab”), does not charge transaction fees for U.S. listed equities and
exchange traded funds. Since we pay the transaction fees charged by the custodian to clients
participating in our wrap fee program, this presents a conflict of interest because we are incentivized
to recommend equities and exchange traded funds over other types of securities in order to reduce
our costs.
Our Wrap Advisory Services
Wrap Asset Management:
We emphasize continuous and regular account supervision. As part of our asset management service,
we create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options,
mutual funds and other public and private securities or investments. The client’s individual investment
strategy is tailored to their specific needs and may include some or all of the previously mentioned
securities. Each portfolio will be initially designed to meet a particular investment goal, which we
determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been
determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based
upon the client’s individual needs, stated goals, and objectives. Each client has the opportunity to place
reasonable restrictions on the types of investments to be held in the portfolio.
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 Bridgewater Asset Management, LLC]
Assets Under Management is defined as the accumulated total of all accounts held within a client
household. Other non-advisory assets may be included by the advisor at their discretion.
Fee Schedule:
Assets Under Management Maximum Annual Percentage of
Assets Charge
$0 to $250,000 1.60%
$250,000 to $499,999 1.35%
$500,000 to $999,999 1.10%
$1,000,000 to $1,999,999 1.00%
$2,000,000 to $3,999,999 0.95%
Over $4,000,000 0.90%
When establishing the asset charge for a specific account, the advisor will consider various factors
which include the size of the account, trading frequency and transactions cost imposed. There are
instances when the advisor will assess a lower asset charge to offset the cost of transaction charges
or the selection of higher share classes which do not assess a transaction charge. The goal being to
establish a total cost that is equivalent or lower than
the asset management schedule above.
Our fees may be negotiable. Our firm bills on cash unless indicated otherwise in writing. Fees will be
automatically deducted from your managed account. In rare cases, we will agree to direct bill clients.
Clients custodied with LPL Financial (“LPL”):
Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the
value of your account on the last day of the previous quarter. Our fees may be negotiable.
Fees will be automatically deducted from your managed account. LPL will make quarterly
adjustments for deposits and withdrawals in client accounts. As part of this process, you
understand and acknowledge the following:
a) LPL Financial as the custodian sends statements at least quarterly to Clients showing
all disbursements for their account, including the amount of the advisory fees paid to
our firm;
b) The Client has provided written authorization permitting fees to be directly paid by
these terms;
c) LPL Financial calculates the advisory fees and deducts them from the Client’s account.
Clients custodied with Charles Schwab & Co., Inc. (“Schwab”):
Our firm’s fees are billed on a pro-rata basis quarterly in arrears based on the value of the
account(s) on the market value of the account at the end of the quarter. Adjustments will be
made for deposits and withdrawals during the quarter. As part of this process, you
understand and acknowledge the following:
a) The client’s independent custodian sends statements at least quarterly showing the
market values for each security included in the Assets and all account disbursements,
including the amount of the advisory fees paid to our firm;
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 Bridgewater Asset Management, LLC]
b) Clients will provide authorization permitting our firm to be directly paid by these terms.
Our firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
We will review your annual percentage of assets charge at least annually to determine consistency
with the state fee schedule shown above.
If the client wishes to terminate our services, the client will need to contact us in writing and state
that they wish to cancel the Agreement. Upon receipt of the letter of termination, we will proceed to
close out the account and process a pro-rata refund of unearned advisory fees, if our fees are charged
in advance. If our fees our charged in arrears, the pro-rata advisory fees for services rendered will be
deducted from the client’s managed account(s). If advisory fees cannot be deducted, our firm will
send the client an invoice for due advisory fees.
For the purposes of calculating refunds, all work performed by us up to the point of termination shall
be calculated by dividing the advisory fee by the number of the days of the quarter. We’ll multiply
that rate by the number of days before you terminate our service to determine the amount of the
client’s refund. LPL Financial will refund your account directly.
You may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange
traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other
fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and
other fees and taxes on brokerage accounts and securities transactions. These fees are not included
within the wrap-fee you are charged by our firm.
We do not recommend or offer the wrap program services of other providers. Our investment
advisory representatives receive a portion of the advisory fee that you pay us, either directly as a
percentage of your overall fee or as their salary from our firm. In cases where our investment
advisory representatives are paid a percentage of your overall advisory fee, this may create an
incentive to recommend that you participate in a wrap fee program rather than a non-wrap fee
program (where you would pay for trade execution costs) or brokerage account where commissions
are charged. This is because, in some cases, we may stand to earn more compensation from advisory
fees paid to us through a wrap fee program arrangement if your account is not actively traded.