We offer a wrap fee program as described in this Wrap Fee Program Brochure. A wrap fee program is generally
considered any arrangement under which clients receive investment advisory services and the execution of client
transactions for a specified fee or fees not based upon transactions in their accounts. All of our investment
management clients will be offered the wrap fee program structure that includes, as a single fee, the securities
transaction costs for trading in Client accounts along with the investment advisory fees earned by our firm. Our firm
receives a portion of the wrap fee for the services rendered. While traditional Wrap Fee Programs are often rigid,
pre-packaged investment programs, our firm customizes its investment strategies individually for its Clients. Prior to
receiving services through the Program, clients are required to enter into a written agreement with our firm setting
forth the relevant terms and conditions of the investment advisory relationship (the “Agreement”).
OUR WRAP ADVISORY SERVICES
We manage advisory accounts on a non-discretionary and discretionary basis. Once we determine a client’s profile,
income need, and investment plan, we execute the day-to-day transactions with or without prior consent,
depending on the client’s agreement with our Firm. Account supervision is guided by the client’s written profile and
investment plan. We may accept accounts with certain restrictions if circumstances warrant. We primarily allocate
client assets among various equities, Exchanged Traded Funds (“ETFs”), mutual funds and debt securities in
accordance with their stated investment objectives and income needs.
In personal discussions with clients, we determine their objectives, time horizons, risk tolerance and liquidity and
income needs. As appropriate, we also review their prior investment history, as well as family composition and
background. Based on client needs, we develop the client’s personal profile and investment plan. We then create
and manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us
immediately if circumstances have changed with respect to their goals and income needs.
Once we have determined the appropriate strategy for clients or client businesses and executed the strategy, we
will provide ongoing investment review and management services. This approach requires us to periodically review
client portfolios.
With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet your
financial objectives. We trade these portfolios based on the combination of our market views and your objectives,
using our investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure
that your portfolio is managed in a manner consistent with those needs and objectives. You will have the ability to
leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of
securities.
If a non-discretionary relationship is in place, calls will be placed to the client presenting the recommendation made
including a rebalancing recommendation and only upon your authorization will any action be taken on your behalf.
Occasionally our Firm utilizes the services of a TPMM for the management of client accounts. Investment advice
and trading of securities will only be offered by or through the chosen TPMM. Our Firm will not offer advice on any
specific securities or other investments in connection with this service. Prior to referring clients, our Firm will provide
initial due diligence on TPMM and ongoing reviews of their management of client accounts. In order to assist in the
selection of a TPMM, our Firm will gather client information pertaining to financial situation, investment objectives,
and reasonable restrictions to be imposed upon the management of the account.
Our Firm will periodically review third party money manager reports provided to the client at least annually. Our
Firm will contact clients from time to time in order to review their financial situation and objectives; communicate
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information to TPMM as warranted; and, assist the client in understanding and evaluating the services provided by
the TPMM. Clients will be expected to notify our Firm of any changes in their financial situation, investment
objectives, or account restrictions that could affect their financial standing.
The TPMM recommended for the portfolio may have higher or lower fees than other programs available through
Palatine Hill or available elsewhere. Investment management programs may differ in the services provided and
method or type of management offered, and each may have different account minimums. Client reports will depend
upon the management program selected. TPMM fees and services will be indicated on your Investment Advisory
Agreement. The TPMM fee is in addition to the investment advisory fee charged by Palatine Hill. The combined
advisory fee billed by Palatine Hill and the TPMM fee are not to exceed 2.00%.
The services provided by the TPMM include:
▪ Assessment of the client's investment needs and objectives.
▪ Implementation of an asset allocation.
▪ Delivery of suitable style allocations (e.g., Large Cap, Small Cap, Growth, Value, etc.)
▪ Facilitation of portfolio transactions.
▪ Ongoing monitoring of investment vehicles performance.
▪ Review of client accounts for adherence to policy guidelines and asset allocation.
▪ Recommendations for account re-balancing, if and when necessary.
▪ Reporting of client portfolio performance and progress.
▪ Engaging selected investment vehicles on behalf of the client
Please see complete details in the program brochure and custodial account agreement for each program
recommended and offered.
A TPMM relationship may be terminated at the IAR’s discretion. Palatine Hill may at any time terminate the
relationship with
a TPMM that manages your assets. Palatine Hill will notify you of instances where we have
terminated a relationship with any TPMM you are investing with. Palatine Hill will not conduct on-going supervisory
reviews of the TPMM following such termination.
Factors involved in the termination of a TPMM may include a failure to adhere to their stated management style or
your objectives, a material change in the professional staff of the TPMM, unexplained poor performance,
unexplained inconsistency of account performance, or our decision to no longer include the TPMM on our list of
approved TPMMs.
You are advised and are expected to understand that our past performance is not a guarantee of future results.
Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital
losses in your account.
RELATIVE COST OF THE PROGRAM
A wrap fee program allows our clients to pay a specified fee for investment advisory services and the execution of
transactions. Clients do not pay brokerage commissions, markups or transaction charges for execution of
transactions in addition to the advisory fee however, most investments trade without transaction fees today, so our
payment of these and other incidental custodial related expenses should not be considered a significant factor in
determining the relative value of our wrap program.
Our Firm charges an advisory fee as compensation for providing Investment Management services on client
accounts. These services include advisory services, investment supervision, and other account-maintenance
activities. Our custodian charges custodial fees, redemption fees, retirement plan and administrative fees or
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commissions. Financial planning services by our firm are included in advisory fees outlined below. See Additional
Fees and Expenses below for additional details.
The fees for investment management are based on an annual percentage of assets under management and are
applied to the household asset value on a pro rata basis. Fees are billed quarterly in advance based on the average
daily balance of the account(s) during the previous quarter. Fees may be adjusted for deposits and withdrawals
during the previous quarter. Fees are assessed on all assets under management, including securities, cash, and
money market balances. Margin account balances are not included in the fee billing.
Our maximum investment advisory fee is 1.00%, or we may negotiate a lower advisory fee. The specific advisory fees
are set forth in your Investment Advisory Agreement. Fees may vary based on the size of the account, complexity
of the portfolio, extent of activity in the account, or other reasons agreed upon by us and you as the client. In certain
circumstances, our fees and the timing of the fee payments may be negotiated. Our employees and their family
related accounts are charged a reduced fee for our services.
Unless otherwise instructed by the Client, we will aggregate related client accounts for the purposes of determining
the account size and annualized fee. The common practice is often referred to as “householding” portfolios for fee
purposes and may result in lower fees than if fees were calculated on portfolios separately. Our method of
householding accounts for fee purposes looks at the overall family dynamic and relationship. When applicable and
noted in the Investment Management Agreement, concentrated stock positions may also be excluded from the fee
calculation.
The independent qualified custodian holding your funds and securities will debit your account directly for the
advisory fee and pay that fee to us. You will provide written authorization permitting the fees to be paid directly
from your account held by the qualified custodian. At our discretion, you may pay the advisory fees directly to our
Firm by check. Further, the qualified custodian agrees to deliver an account statement to you on a quarterly basis
indicating all the amounts deducted from the account including our advisory fees.
Either party giving written or verbal notice to the other may cancel the Investment Advisory Agreement at any time
for any reason. Notice given by the client shall be effective upon actual receipt by Palatine Hill at the address
specified on the Investment Advisory Agreement or the then current address. The management fee will be pro-
rated to the date of termination, for the quarter in which the cancellation notice was given and the earned fee billed
to your account as indicated in your Agreement. Upon termination, you are responsible for monitoring the securities
in your account, and we will have no further obligation to act or advise with respect to those assets. In the event of
client’s death or disability, our Firm will continue management of the account until we are notified of client’s death
or disability and given alternative instructions by an authorized party.
In no case are our fees based on, or related to, the performance of your funds or investments.
Palatine Hill is the sponsor and portfolio manager of this Wrap Fee Program. Palatine Hill receives investment
advisory fees paid by our clients for investment advisory services covered under this Wrap Fee Program.
OTHER TYPES OF FEES & EXPENSES
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, wire transfer fees, fees for trades executed away from custodian, and taxes on brokerage accounts
and securities transactions. These fees are not included within the wrap-fee you are charged by our firm. Neither
our Firm nor its supervised persons accept compensation for the sale of securities. Further, our firm does not share
in any of these additional fees and expenses outlined above.
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