Overview
A. Description of the Advisory Firm
191 Godwin Associates, Inc. (hereinafter “GWC”) provides portfolio management to
clients under this wrap fee program as sponsor and portfolio manager.
Total Assets Under Management Annual Fee
$0 - $200,000 1.00%
$200,001 - $500,000 0.75%
$500,001 - $750,000 0.70%
$750,001 - AND UP 0.65%
These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement.
Fees will be invoiced and billed directly to the client, payable on a basis.
Fees are paid in arrears. GWC uses an average of the daily balance in the client’s account
throughout the billing period, after taking into account deposits and withdrawals, for
purposes of determining the market value of the assets upon which the advisory fee is
based.
Clients may terminate the agreement without penalty, for full refund of GWC ’s fees,
within five business days of signing the Investment Advisory Contract. Thereafter, clients
may terminate the Investment Advisory Contract generally with 1 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
GWC will wrap third party fees (i.e., custodian fees, brokerage fees, mutual fund fees,
transaction fees, etc.) for wrap fee portfolio management accounts. GWC 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 GWC 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, 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.
D. Compensation of Client Participation
Neither GWC, nor any representatives of GWC 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, GWC may
have a financial incentive to recommend the wrap fee program to clients.