A. Description of the Advisory Firm
B. Types of Advisory Services
to seek fair and equitable allocation of investment opportunities/transactions among its
clients to avoid favoring one client over another over time. It is Brainvest’s policy to allocate
investment opportunities and transactions it identifies as being appropriate and prudent,
including initial public offerings ("IPOs") and other investment opportunities that might have
a limited supply, among its clients on a fair and equitable basis over time.
Pension Consulting Services
Brainvest offers consulting services to pension or other employee benefit plans (including but
not limited to 401(k) plans). Pension consulting may include, but is not limited to:
o identifying investment objectives and restrictions
o providing guidance on various assets classes and investment options
o recommending money managers to manage plan assets in ways designed to achieve
objectives
o monitoring performance of money managers and investment options and making
recommendations for changes
o recommending other service providers, such as custodians, administrators and
broker-dealers
o creating a written pension consulting plan
These services are based on the goals, objectives, demographics, time horizon, and/or risk
tolerance of the plan and its participants.
Pooled Investment Vehicles
Brainvest acts as the Portfolio Manager or advisory capacity to a variety of U.S. and non-U.S.
pooled investment vehicles. These arrangements are disclosed in each fund’s prospectus or
offering document in accordance with applicable disclosure requirements.
Services Limited to Specific Types of Investments
Brainvest generally limits its investment advice to mutual funds, fixed income securities, real
estate funds (including REITs), insurance products including annuities, equities, ETFs
(including ETFs in the gold and precious metal sectors),
treasury inflation protected/inflation
linked bonds, commodities, non-U.S. securities, venture capital funds and private
placements. Brainvest may use other securities as well to help diversify a portfolio when
applicable.
Brainvest will tailor a program 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 executed
by Brainvest on behalf of the client. Brainvest may use model allocations together with a specific
set of recommendations for each client based on their personal restrictions,
C. Client Tailored Services and Client Imposed Restrictions
needs, and targets. Clients may impose restrictions in investing in certain securities or types of
securities in accordance with their values or beliefs. However, if the restrictions prevent
Brainvest from properly servicing the client account, or if the restrictions would require
Brainvest to deviate from its standard suite of services, Brainvest reserves the right to end the
relationship.
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.
Brainvest does not participate in any wrap fee programs.
Brainvest has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$1,094,619,780
$2,805,927
December 2022
Portfolio Management Fees
Total Assets Under Management Annual Fees
US $0 to US$ 999,999 1.50%
US $1,000,000 to US $4,999,000 1.00%
US $5,000,000 to US $9,999,999 0.85%
US $10,000,000 to US $19,999,999 0.65%
US $20,000,000 and above 0.50%
Brainvest will charge a management fee on a per annum basis of the Client’s net assets under
management, according as per agreed schedule. The management fee will be calculated
D. Wrap Fee Programs
E. Assets Under Management