This Wrap Fee Brochure describes the services, fees and other information Clients may need to consider prior to
participating in the wrap fee program (the “Program”) offered by Aghaz. Additional information about the Firm
can be found in SEC Form ADV Part 1A and Part 2A, which can be found at
www.adviserinfo.sec.gov.
Types of Advisory Services
Aghaz’s portfolio management and investment advisory services are offered to Clients. The types of Clients to
which Aghaz provides investment management services are more fully disclosed in Aghaz’s Form ADV Part 1 and
summarized in
Item 7 – Types of Clients of the ADV Part 2A Brochure.
The Firm is a Sharia-compliance advisory firm. The Shariah Screening Criteria is developed by our Shariah
Advisors is that the business of the investee company must be Halal. In other words, the investee companies with
the following core businesses will be excluded:
• Companies involved in interest-based lending or interest-based products
• Manufacturing or distribution of alcohol and other non-halal drinks
• Manufacturing or distribution of cigarettes and other non-halal foods
• The production, packaging, processing, or any activity related to pork
• Companies operating in betting and gambling operations
• Production and distribution or sale of music or pornography
• Companies involved in human genetic manipulation
• Other activities as determined by the Shariah Advisor
Once an investee company has cleared the above the screening, it is screened on the following parameters to ensure
that exposure to unlawful income is absolutely minimal and that the impure income can be purified.
• The interest bearing debt must not exceed 30% of the market capitalization.
• The interest-bearing instruments or other non-compliant investments must not exceed 30% of the market
capitalization.
• Non-compliant source of income must not exceed 5 percent of the total gross revenue earned by the
company.
Aghaz advisory services consist of portfolio management to clients under a wrap fee program as sponsor and
portfolio manager. A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, and certain other administrative fees. The Company provides robo-
advisory portfolio management to clients under this wrap fee program as sponsor and portfolio manager via an
online interface. This entails the use of algorithm-based portfolio management advice, rather than in-person
investment advice. These automated investment solutions are customized to each client and based on individual
characteristics, such as the client’s age, risk tolerance, income, and current assets, among others. Aghaz generally
is responsible for investing and re-investing the assets of each Client account in accordance with the investment
objectives, policies and guidelines set forth in the Client’s governing documents.
Aghaz tailors its investment advice to the specific needs of its Clients and is subject to applicable investment
restrictions set forth in the governing documents for the applicable Clients. Aghaz works with Clients to formulate
appropriate and agreed-upon investment guidelines. Aghaz works with Clients to determine the feasibility of
monitoring proposed restrictions and limitations. Clients who restrict their investment portfolios may experience
potentially worse performance results than Clients with unrestricted portfolios even for Clients with similar
objectives. Aghaz reserves the right to reject or terminate any Client that seeks restrictions which Aghaz is unable
to implement, or which may fundamentally alter the investment objective of the strategy selected by the Client.
When Aghaz serves as investment adviser, it enters into a written investment management agreement with each of
its advisory Clients. Investment management agreements include provisions related to each Client’s management
fees, investment strategy, investment guidelines, termination rights, proxy voting and sub-adviser, if applicable. In
summary, Aghaz provides the following advisory services:
• Discretionary Investment Management, except as otherwise set forth in any
applicable Client Agreement. Our Clients authorize Aghaz to investigate, purchase,
and sell on behalf of Client, various securities and investments. Aghaz is authorized
to execute purchases and sales of securities on Client’s behalf without consulting
Client regarding each sale or purchase. Client may, however, terminate the
discretionary authority of Aghaz immediately upon written notice.
• Non-Discretionary Investment Management. In these types of Client Agreements,
Aghaz is authorized to execute purchases and sales of securities only after securing
permission from Client regarding each transaction.
Aghaz will not select outside portfolio managers for management of its wrap fee program. Aghaz will be the sole
portfolio manager for the wrap fee program. Aghaz will use industry standards to calculate portfolio manager
performance. Aghaz reviews the performance information to determine and verify its accuracy and compliance
with presentation standards. The performance information is annually and is reviewed by Aghaz.
The Company and its personnel serve as the portfolio managers for all wrap fee program accounts. This is a conflict
of interest in that no outside adviser assesses Aghaz’s management of the wrap fee program. However, Aghaz
addresses this conflict by acting in its clients’ best interest consistent with its fiduciary duty as sponsor and portfolio
manager of the wrap fee program.
Fees and Compensation: Investment Advisory Services
Clients participating in the Program will be charged a single “wrap” fee. Below is our general fee schedule,
however, fees may be negotiated at Aghaz’s sole discretion. The specific way we charge fees is established in your
written agreement with us.
Aghaz’s fees are fixed. The fixed fee will be a subscription fee of $2 per month, plus 0.49%per year. Fees are paid in
arrears. Clients may terminate the agreement without penalty, for full refund of AGHAZ’s fees, within five business
days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory
Contract immediately upon written notice.
In addition, there are contribution cost factors. For example, the program may cost the client more or less than
purchasing such services separately. There are several factors that bear upon the relative cost of the program,
including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the
services if provided separately (which in turn depends on the prices and specific services offered by different
providers). For example, Clients may incur operating and transaction fees, costs and expenses associated with
maintaining their accounts imposed by custodians, brokers, futures commission merchants, prime brokers and
other third parties. Examples of these charges include but are not limited to custodial fees, margin, deferred sales
charges, “mark-ups” and “mark-downs” on trades, odd-lot differentials, transfer taxes, handling charges, exchange
fees (including foreign currency exchange fees), interest to cover short positions, wire transfer fees, electronic fund
fees, conversion fees for American Depository Receipts (“ADRs”) and other fees and taxes on brokerage accounts
and securities transactions.
Aghaz does not receive any portion of these commissions, fees or costs. See, however,
Item 12 – Brokerage Practices of the ADV Part 2A Brochure for more information about soft-dollars. See also Item 12
– Brokerage Practices of the ADV Part 2A Brochure for more information about conversion fees for ADRs.
Aghaz will wrap third party fees (i.e., custodian fees, brokerage fees, transaction fees, etc.) for wrap fee portfolio
management accounts. Aghaz will charge clients one fee and pay all transaction fees using the fee collected from
the client. Certain other fees are not included in the wrap fee and are paid for separately by the client. These include,
but are not limited to, margin costs, charges imposed directly by Sukuk ETFs (fixed income instruments) or
exchange traded fund, fees associated with “step out” transactions if the account uses different custodians or
broker-dealers, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees,
and other fees and taxes on brokerage accounts and securities transactions.
Neither Aghaz, nor any representatives of Aghaz receive any additional compensation beyond advisory fees for
the participation of client’s in the wrap fee program. However, compensation received may be more than what
would have been received if client paid separately for investment advice, brokerage, and other services. Therefore,
Aghaz may have a financial incentive to recommend the wrap fee program to clients.
Other Fees Charged
In addition to the fees described above, Clients may bear other costs associated with investments or accounts
including but not limited to: (i) custodial charges, brokerage fees, commissions and related costs; (ii) interest
expenses; (iii) taxes, duties and other governmental charges; (iv) transfer and registration fees or similar expenses;
(v) costs associated with foreign exchange transactions; (vi) other portfolio expenses; and (vii) costs, expenses and
fees (including investment advisory and other fees charged by the investment advisers of funds in which the
Client’s account invest) associated with products or services that may be necessary or incidental to such
investments or accounts. With respect to such services (which may include, but are not limited to, custodial,
securities lending, brokerage, futures, banking, consulting or third-party advisory or legal services) each Client
may be required to establish business relationships with relevant service providers or other counterparties based
on the Client’s own credit standing. Aghaz will not have any obligation to allow its credit to be used in connection
with the establishment of such relationships, nor is it expected that such service providers or counterparties will
consider or rely on Aghaz’s credit in evaluating the Client’s creditworthiness.
Custodian Fees
Clients may be charged the following fees from their account custodian or executing broker: charges for transactions
with respect to assets not executed through the custodian; short term redemption costs; costs charged to
shareholders of mutual funds and exchange traded funds by the fund manager; odd-lot differentials; American
Depository Receipt costs; costs associated with exchanging currencies; or other costs required by law.
Administrative costs for retirement accounts and any platform (technology) fees are paid directly by the Client,
unless other arrangements have been made.
Additionally, the Client will be charged for non-standard service fees incurred as a result of any special requests
made by the Client, such as overnight courier or wiring fees. Account custodians may also charge clients account
transfer and/or termination fees.
For custodial services, Aghaz utilizes the services of a number of firms to meet its Clients’ needs. Custodial
transaction fees (for transactions executed through the custodian’s broker-dealer) may be paid by the Client or by
Aghaz as negotiated and stated in the Client’s agreement with the account custodian. Custodians charge Clients
other fees, beyond transaction fees. The additional fees charged to Clients by the custodian may include, but are
not limited to, fees related to custodial and clearing agent services, maintenance of portfolio accounting systems,
preparation and mailing of Client statements, account processing, systematic withdrawals, redemptions,
terminations, account transfers, retirement account custodial services (except for the retirement account
termination cost), maintenance of a Client inquiry system, as well as execution of securities transactions in the
Client’s account. None of these charges are retained by Aghaz.
Terminated Accounts
The Firm’s standard investment management contract generally continue in effect until terminated by either party
upon written or verbal notice to the other (email notice will suffice). Upon the termination of the Agreement,
Adviser will have no obligation to recommend or take any action with regard to the securities, cash or other
investments in the account. In the event the Agreement is terminated, and the Client has prepaid fees which have
been unearned as of the date of termination, such unearned fees shall be immediately refunded to the Client. The
Client will be charged for all days their account is managed up and including the day the Client requests a
termination. The Client will receive a prorate refund of the number of days remaining in the quarter starting the
day after termination request is received. Please note, it is possible for unearned fees to be adjusted and not be
made available to the Client under certain circumstances, for example in situations where the fee is below a de
minimis dollar threshold of $100.00.
In addition, upon execution of an investment advisory agreement, the Client acknowledges receipt of Part 2 of
Form ADV; a disclosure statement containing the equivalent information; or a disclosure statement containing at
least the information required by Part 2A Appendix 1 of Form ADV, if the Client is entering into a wrap fee program
sponsored by the investment adviser. If the appropriate disclosure statement was not delivered to the Client at least
48 hours prior to the Client entering into any written or oral advisory contract with this investment adviser, then
the Client has the right to terminate the contract without penalty within five business days after entering into the
contract. For the purposes of this provision in our Agreements, a contract is considered entered into when all parties
to the contract have signed the contract, or, in the case of an oral contract, otherwise signified their acceptance, any
other provisions of this contract notwithstanding. Importantly, upon termination, a Client is responsible for
monitoring the securities in his or her 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, Aghaz will continue management of the account until
we are notified of Client’s death or disability and given alternative instructions by an authorized party.
Generally, upon notice of termination to the Client, the Firm will begin the process of removing its access to the
Client’s account; however, the custodian may require a reasonable amount of time to liquidate and/or transfer
assets, including time for required recordkeeping, processing, and complying with the rules and conditions
imposed by mutual fund companies, stock exchanges, or securities issuers.