R. Seeger Wealth Management, LTD (hereinafter “RSWM”) offers the following services to
advisory clients:
A. Description of Services
RSWM participates in and sponsors wrap fee programs, which means RSWM will wrap
third party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees,
etc.) for wrap fee portfolio management accounts. RSWM will charge clients one fee and
pay all transaction fees using the fee collected from the client. Accounts participating in
the wrap fee program are not charged higher advisory fees based on trading activity, but
clients should be aware that RSWM has an incentive to limit trading activities for those
accounts since the firm absorbs those transaction costs.
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 a mutual
fund or exchange traded fund, 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.
The fee schedule is set forth below:
Total Assets Under Management Annual Fee
$100,000 - $150,000 1.25%
$150,001 - $1,750,000 1.00%
$1,750,001 - $4,000,000 .75%
$4,000,001 – And Up .60%
These fees are negotiable depending upon the needs of the client and complexity of the
situation and the final fee schedule is attached as Exhibit II of the client contract. RSWM
uses the last day of previous quarter for purposes of determining the market value of the
assets upon which the
advisory fee is based.
Advisory fees are withdrawn directly from the client’s accounts with client written
authorization. Fees are paid quarterly in arrears. Because fees are charged in arrears, no
refund policy is necessary.
Clients may terminate the contract without penalty, for full refund, within five business
days of signing the contract. Thereafter, clients may terminate the contract with thirty
days’ written notice.
B. Contribution Cost Factors
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).
C. Additional Fees
Clients who participate in the wrap fee program will not have to pay for transaction or
trading fees. However, clients are still responsible for all other account fees, such as
mutual fund fees.
D. Compensation of Client Participation
Neither RSWM, nor any representatives of RSWM receive any additional compensation
beyond advisory fees for the participation of clients 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, RSWM may
have a financial incentive to recommend the wrap fee program to clients.