SERVICES
We offer portfolio management services that involve assisting with the ongoing management of
a client’s investment accounts. We work with the client to formulate an individualized portfolio
based upon his or her objectives, time frame, risk parameters, and other investment
considerations. Once we have this information, we create an individualized portfolio for the
client. We regularly monitor the client’s portfolio and adjust it as determined by the stock
market and world events.
FEES
Our wrap management fee is based on a percentage of assets under management, including
the assets purchased on margin, in the client’s account. The annual wrap management fee is no
more than 2.00%. The wrap management fee is negotiable based on the size of the account.
The client may aggregate or household accounts to negotiate a lower wrap management fee.
Our wrap management fee is billed quarterly, in advance. This means we collect the wrap
management fee at the beginning of the quarterly billing period. The wrap management fee
will be based on the custodian reported account value as of the last business day of the prior
quarter. The management fee is not adjusted for deposits or withdrawals during the billing
period. Accounts established during a calendar quarter will be charged a prorated wrap
management fee. The wrap management fee will be deducted directly from the client’s account
unless special arrangements have been made. Cash balances and investments in money market
funds held in the account are counted toward the account value and are included in the wrap
management fee calculations.
In a wrap account, the client pays a single annual wrap management fee for advisory services
and execution of transactions. The client does not pay brokerage commissions, markups, or
transaction charges for execution of transactions in addition to the management fee.
Termination of Wrap Program Services
The client may terminate the wrap program agreement for any reason at any time and. If the
client terminates the wrap program within the first five (5) business days after signing the
contract, the client will receive a 100% refund of any prepaid management fees, without any
cost or penalty. Thereafter, either party may terminate the wrap program agreement by giving
the other party ten (10) days’ written notice of termination. Upon our receipt of the client’s
written notice of termination, the client will receive a prorated refund of the wrap
management fee based on the amount of time services were rendered during the termination
quarter. For example, if there are 90 days in a quarter and the service was cancelled after 45
days, the client will receive a 50% refund of the quarterly wrap management fee (45 divided by
90 equals 50%). Refunds are paid by depositing the prorated portion of the wrap management
fee back into the account, if allowed by the client’s custodian. In all other cases refunds are paid
by check.
Other Types of Fees and Charges
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The client may pay custodial fees, fees for trades executed away from the custodian, charges
imposed directly by a mutual fund, index fund, or exchange traded fund as 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
management fee that is charged by us.
There are other fees and charges that are imposed by other third parties that apply to
investments in program accounts. Some of these fees and charges are described below:
If a client’s assets are invested in mutual funds or other pooled
investment products, clients
should be aware that there will be two layers of advisory fees and expenses for those
assets. Client will pay an advisory fee to the fund manager and other expenses as a
shareholder of the fund. Client will also pay us the wrap management fee with respect to
those assets. Most of the mutual funds available in the program may be purchased directly.
Therefore, clients could generally avoid the second layer of fees by not using our
management services and by making their own investment decisions.
Certain mutual funds impose fees and charges such as contingent deferred sales charges,
early redemption fees, and charges for frequent trading. These charges may apply if the
client transfers into or purchases such a fund with the applicable charges in a program
account.
Although only no-load and load-waived mutual funds can be purchased in a program
account, clients should understand that some mutual funds pay asset-based sales charges
or service fees (e.g., 12b-1 fees) to the custodian with respect to account holdings.
Further information regarding fees assessed by a mutual fund is available in the appropriate
prospectus, which is available upon request from us or from the product sponsor directly.
Other Important Considerations
The wrap management fee is an ongoing wrap fee for investment advisory services, the
execution of transactions and other administrative and custodial services. The wrap
management fee may cost the client more than purchasing the program services separately,
because the client could pay an advisory fee plus commissions for each transaction in the
account. Factors that bear upon the cost of the account in relation to the cost of the same
services purchased separately include the type and size of the account, historical or
expected size or number of trades for the account, and number and range of
supplementary advisory and client-related services provided to the client.
The wrap management fee also may cost the client more than if assets were held in a
traditional brokerage account. In a brokerage account, a client is charged a commission for
each transaction, and the representative has no duty to provide ongoing advice with
respect to the account. If the client plans to follow a buy and hold strategy for the account
or does not wish to purchase ongoing investment advice or management services, the client
should consider opening a brokerage account rather than a program account.
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The investment products available to be purchased in the program can be purchased by
clients outside of a program account, through broker-dealers or other investment firms not
affiliated with us.
Because we absorb certain transaction costs in wrap fee accounts, we may have a financial
incentive not to place transaction orders in those accounts since doing so increases our
transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee
arrangement.
We do not charge our clients higher advisory fees based on their trading activity, but clients
should be aware that we may have an incentive to limit our trading activities in client
accounts because we are charged for executed trades.
Retirement Rollover Conflicts of Interest
When we recommend you rollover a retirement account for us to manage, this creates a
financial incentive because we charge a fee for our services. We attempt to mitigate the conflict
of interest by acting in your best interest and applying an impartial conduct standard to all
rollovers. Please note that you are not under any obligation to roll over a retirement account to
an account managed by us.