A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ................................9
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ..............................................9
C. Content and Frequency of Regular Reports Provided to Clients .......................................................9
Item 13: Client Referrals and Other Compensation ..........................................................................................10
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales
Awards or Other Prizes) ...................................................................................................................................10
B. Compensation to Non – Advisory Personnel for Client Referrals ...................................................10
Item 14: Custody ....................................................................................................................................................10
Item 15: Investment Discretion ............................................................................................................................10
Item 16: Voting Client Securities (Proxy Voting) ..............................................................................................10
Item 17: Financial Information .............................................................................................................................10
A. Balance Sheet ...........................................................................................................................................10
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to
Clients ..................................................................................................................................................................11
C. Bankruptcy Petitions in Previous Ten Years .......................................................................................11
Item 3: Advisory Business
A. Description of the Advisory Firm
Councilor, Buchanan & Mitchell, P.C. (CBM) (hereinafter “CBM”) is a corporation
organized in the State of Maryland. The firm was formed in January 1921, and there are
no persons who own 25% or more of the company.
B. Types of Advisory Services
Financial Planning
Financial plans and financial planning may include but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Services Limited to Specific Types of Investments
CBM generally limits its investment advice to mutual funds, fixed income securities,
equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation
protected/inflation linked bonds and non-U.S. securities. CBM may use other securities
as well to help diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions
CBM will tailor a financial plan for each individual client. This will include an interview
session to get to know the client’s specific needs and requirements as well as a plan that
will be discussed with the client and executed by the client. CBM may use model
allocations together with a specific set of recommendations for each client based on their
personal restrictions, needs, and targets. Clients may impose restrictions for investment
recommendations of certain securities or types of securities in accordance with their
values or beliefs. However, if the restrictions prevent CBM from properly servicing the
client account, or if the restrictions would require CBM to deviate from its standard suite
of services, CBM reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative
fees. CBM does not participate in any wrap fee programs.
E. Assets Under Management
CBM does not accept any assets under management.
A. Fee Schedule
Financial Planning Fees
Hourly Fees
The hourly fee for these services ranges between $200 and $475.
Clients may terminate the agreement without penalty within five business days of signing
the Financial Planning Agreement. Thereafter, clients may terminate the Financial
Planning Agreement generally upon written notice.
B. Payment of Fees
Payment of Financial Planning Fees
Financial planning fees are paid via check, wire, debit or credit card.
Hourly financial planning fees are invoiced monthly. Upon signing our engagement
letter, CBM requests a retainer to be applied towards fees incurred. Retainers generally
range between $1,000- $3,000.
C. Client Responsibility for Third Party Fees
Clients are responsible for the payment of all third-party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by CBM. Please see Item 11 of this brochure
regarding broker-dealer/custodian.
D. Prepayment of Fees
CBM may collect a retainer in advance. Refunds for fees paid in advance, but not yet
earned, will be refunded upon request within thirty (30) days to the client via check.
For retainer fees that are collected in advance, the fee refunded will be the balance of the
fees collected in advance minus the hourly rate times the number of hours of work that
has been completed up to and including the day of termination.
E. Outside Compensation For the Sale of Securities to Clients
CBM not sell securities to clients. Accordingly, neither CBM nor its supervised persons
accept any compensation for the recommendation or sale of investment products,
including asset-based sales charges or service fees from the sale of mutual funds.