Overview
A. Description of the Advisory Firm
B. Types of Advisory Services
Signaling Services
WS provides investment advisers with a subscription to certain investment selection
models. WS creates and provides signaling services models to the investment advisers
based on parameters they set forth.
Services Limited to Specific Types of Investments
WS generally limits its investment advice to mutual funds, real estate funds (including
REITs), equities, fixed income, ETFs (including ETFs in the gold and precious metal
sectors) and non-U.S. securities. WS may use other securities as well to help diversify a
portfolio when applicable.
WS offers the same suite of services to all investment advisers that are WS clients.
However, specific investment strategies and their implementation are dependent upon
the direction of the investment adviser. WS assists the primary investment adviser in the
development and preparation of an Investment Policy Statement that describes their
overall investment policies, objectives and guidelines, including, without limitation, asset
allocation guidelines and investment restrictions and preferences. WS creates custom
models/sleeves for the primary adviser based on the parameters set forth by the adviser.
The primary investment advisers may impose restrictions on investing in certain securities
or types of securities. WS reserves the right to end any sub-advisory relationship in
accordance with the terms of its agreement with the primary adviser and may end the
relationship for a variety of reasons, including in response to an investment adviser’s
imposition of additional restrictions.
WS does not directly manage any client assets. All assets under the firm’s advice are
offered through “sponsor” firms who should provide their firm’s ADV Brochure at the
time of opening your account.
C. Client Tailored Services and Client Imposed Restrictions
E. Assets Under Management
WS offers its investment
strategy and portfolio modeling services to other investment
advisers, including UMA programs, and WS receives a share of the fees the primary
investment adviser collects from its underlying clients. The notice of termination
requirement and payment of fees for sub-advisory services will depend on the terms of
the WS agreement with the primary investment adviser. The fees received by WS will not
exceed .60% annually. These fees are generally negotiable.
The primary advisers may request that WS’ advisory fees be withdrawn from the
underlying client accounts through the Platform or the investment adviser may be
invoiced for such fees. The primary adviser will pay WS its portion of such advisory fees
in accordance with the applicable sub-advisory contract between WS and the primary
investment adviser, on a monthly or quarterly basis based on the terms of the agreement.
WS’ client, the primary investment adviser, and the primary adviser’s underlying clients
will be responsible for the payment of all third-party fees (including, without limitation,
any custodian fees, brokerage fees, mutual fund fees, distribution fees, shareholder
servicing fees, transaction fees, Platform fees, taxes, fees of other service providers or
consultants engaged by the primary investment adviser, etc.). Those fees are separate and
distinct from the fees and expenses charged by WS. WS, or our affiliate, receives a portion
of fees charged by Platforms. Item 10 further describes this arrangement and the conflicts
of interest presented.
Please see Item 12 of this brochure regarding brokerage practices.
WS generally collects fees in advance on a quarterly basis. Certain primary advisers may
be billed monthly or quarterly in arrears. Refunds for fees paid in advance will be returned
to the primary adviser.
For all asset-based fees paid in advance, the fee refunded will be equal to the balance of
the fees collected in advance minus the daily rate* times the number of days elapsed in