Services
E6 Portfolios, LLC (“the Firm,” “the Adviser”) was founded on April 18, 2023 and registered as
an RIA on July 13, 2023. The firm is organized as a Limited Liability Company in the state of
Utah and is wholly owned by E6 Holding, LLC.
The Firm operates a Turnkey Asset Management Platform (“TAMP”) that is offered to
registered investment advisers (“RIAs”). The Firm also provides investment management
solutions to clients of wealth management RIAs through its Wrap Fee Programs described
below. The Adviser’s principal place of business is in Midvale, UT.
This Wrap Fee Program Brochure is provided as a supplement to E6 Portfolios’ Disclosure
Brochure (Form ADV 2A). It is provided along with the complete Disclosure Brochure to
provide full details of the business practices and fees when selecting E6 Portfolios for
investment advisory services.
As of February 29, 2024, E6 Portfolios managed $4,785,625 in discretionary assets and $0 in
non-discretionary assets through its Wrap Fee Program.
Wrap Fee Program Services
E6 Portfolios, LLC participates in and sponsors two separate but interdependent Wrap Fee
Programs. Wrap fee programs offer clients investment management as well as transaction and
clearing services for one inclusive fee. E6 Portfolios Wrap Fee Programs require clients to grant
the firm trading discretion over the accounts under management.
The first Wrap Fee Program, described in this brochure, offers Separately Managed Accounts
(SMA), Separately Managed Portfolios (SMP), and Unified Managed Portfolio (UMP) services to
clients.
The second, described in the firm’s E6 Portfolios Strategists Wrap Fee Brochure, offers clients a
menu of specific security models called Investment Strategists. SMA, SMP, and UMP clients use
these models alone or in combination to deliver a balance of risk and opportunity that
corresponds to their investment objectives and risk tolerance.
E6 Portfolios offers only investment management services. Investment advisory services
(sometimes called “Wealth Management”) are not included in E6 Portfolio offerings. Clients
who want to receive Wealth Management services can engage a Registered Investment
Advisory firm other than E6 Portfolios for these services.
Wrap Fee Program Services available only to Clients of Third-Party RIAs
E6 Portfolios will work with third-party Investment Advisors. All of the offerings described in
this brochure allow the Client to authorize a third-party Investment Advisor to communicate
instructions to E6 Portfolios on their behalf. However, not all E6 Portfolios Wrap Fee Programs
are available to all third-party advisors and E6 Portfolios reserves the right to vet third-party
Advisors and elect not to work with any third-party Advisor at its sole discretion.
The clients of the RIAs served by E6 Portfolios are not always in direct contact with the Firm. It
is the responsibility of each third-party RIA to determine their client’s individual financial
situation, investment goals and objectives, qualification, time horizon, portfolio liquidity and
concentration, and tolerance for risk as well as any investment limitations and reasonable
restrictions for their clients’ accounts. E6 Portfolios, in turn, provides investment management
services based on the asset allocation and the investment portfolios selected by the third-party
RIA for their client’s account(s).
Each third-party RIA is responsible for maintaining communication with their clients to monitor
their investment objectives as well as any changes in their client’s individual circumstances. The
RIA is also responsible for communicating any changes about their client(s) financial situation
and investment objectives to E6 Portfolios. Clients of the third-party RIA also bear a
responsibility to communicate changes in their investment objectives and risk profile to the
third-party RIA. Clients should direct their questions about the suitability of E6 Portfolios’
investment strategies and fees charged to their primary RIA. It is the sole responsibility of their
RIA to determine whether our TAMP services and the services provided under our Wrap Fee
Programs are suitable for them.
Third-party RIAs, E6 Portfolios, and their mutual clients all agree to the terms described in this
section by executing a Tri-Party Agreement. Please refer to that agreement for more
information.
E6 Portfolios SMA, SMP, and UMP Services
Separately Managed Accounts (SMA) and Separately Managed Portfolios (SMP) provide
platform access and reporting to clients for a flat monthly fee. Both allow for tax-loss
harvesting strategies, defensive capabilities, and allow the client to customize their overall
portfolio strategy using one or more Investment Strategists across multiple accounts. Both
allow the use of different tools for each account type, including individual securities, ETFs
and/or mutual funds. These tools are intended to minimize cost and maximize tax-efficiency
and give clients the ability to select investments that reflect their values, beliefs, and other
considerations unique to each client.
The offerings differ as follows:
Separately Managed Accounts (SMA) allow the Client’s third-party RIA acting on their behalf to
select a specific Risk Score and Strategist model for each account opened.
Separately Managed Portfolios (SMP) allow the Client’s third-party RIA acting on their behalf to
select a Risk Score and Strategist model for their entire household. Within this household Risk
Score the Client’s third-party RIA can assign a different Risk Score to individual accounts within
the household for tax optimization, cash management, or other purposes in arriving at the
aggregate target Risk Score.
In the SMA program, the Client’s third-party RIA may pay E6 Portfolios a fee but the client does
not pay any fee for this service.
SMA and SMP offerings also differ in their custodial availability (see below) and in their cost to
the Client.
In the SMP program, Clients pay a flat monthly fee of $5.00 per account.
Unified Managed Portfolios (UMP) include the capabilities of the SMA and SMP offerings and
adds management of an entire household as a single, coordinated portfolio. UMP adds more
flexible tax-loss harvesting, asset location strategies, and additional defensive capabilities with
the objective of maximizing liquidity and unique tax characteristics of different account types.
These additional services include placing investments with different risk profiles, tax
characteristics, and expected returns in the most tax-appropriate account type, managing
income, mitigating realized and unrealized taxable gains, utilizing charitable giving to optimize
taxation, managing cash allocations and recurring distributions, rebalancing across multiple
accounts and account types, and coordinating with outside portfolios such as an employer-
sponsored 401(k) or personal investments such as rental property. UMP services are billed as a
percentage of assets under management.
Finally, UMP TLH+ (Tax-loss harvesting+) adds automated daily tax loss harvesting using
primarily individual securities in taxable accounts to maximize after-tax returns.
In both the UMP and UMP TLH+ offerings, the third-party Investment Advisor can bear the cost
of account maintenance and the reporting platform used. For this reason, each Client should
be aware that the third-party advisor can have an incentive to recommend the SMP program
because it costs them less than the SMA or UMP programs.
Availability of Wrap Fee Programs - SMA, SMP, UMP, and UMP TLH+
E6 Portfolios relies on the specific capabilities of the qualified custodians clients use. As a
result, SMA, SMP, UMP, and UMP TLH+ services are available as follows:
Altruist | Fidelity | Interactive Brokers| TradePMR | Employer Plans
SMA X X
SMP X X X X
UMP X X X
UMP TLH+. X X X
Fee Schedule
SMA Wrap Program Flat Fee
$0
SMP Wrap Program Flat Fee
$5.00 / month
UMP Program (Tiered)
Asset Range Fee
$0 - $2,499,999 0.20%
$2,500,000+ 0.00%
UMP TLH+ Program Fee
0.20% (regardless of asset range)
Paper Statement Fees
Electronic communication is the default for E6 Portfolios clients, both for communication
between E6 Portfolios and the client and between the qualified custodian and the client
(statements, trade confirmations, etc.). If the client wishes to receive mailed communication
from the Custodian or from E6 Portfolios the following charges will be assessed:
Paper communications from the custodian: $5 / month
Quarterly Paper Statements from E6 Portfolios: $10 / quarter
Fee Calculation and Manner of Payment
Only one service and fee schedule listed above (SMA, SMP, UMP, or UMP TLH+) applies per
account and the corresponding fee is assessed per account.
The fees for the SMA and SMP Wrap Fee Programs are flat fees charged monthly in arrears for
each corresponding account.
The fees for the UMP and UMP+ Wrap Fee Programs are asset-based fees calculated and
applied based on all assets in the client’s household under management by E6 Portfolios,
excluding SMA or SMP accounts. A “Client household” is generally limited to a person or a
couple who share finances and their minor children; E6 Portfolios reserves the right to
determine the members of a client household.
Asset-based fees are calculated by E6 Portfolios and deducted from the client’s account(s) at
the Custodian. The amount due is calculated monthly in arrears. The monthly rate is calculated
by multiplying the annual rate by the number of days in the previous month and dividing by
365. The monthly rate is then applied to the average daily balance of the account (including
cash) during the month. Fees are deducted from client accounts monthly in arrears. The client’s
agreements with E6 Portfolios and with their qualified custodian provide authorization to
deduct management fees from the client’s account directly and remit that fee to the firm. E6
Portfolios will send a bill to the qualified custodian indicating the amount of the fee to be paid.
The custodian will send a statement to the client, at least quarterly, indicating the fee dispersed
to E6 Portfolios. Each time the fee is assessed, E6 Portfolios will make a statement available to
the client showing the amount of the fee and how the fee was calculated. E6 Portfolios will
disclose to clients their responsibility to verify the accuracy of the fee calculation. Clients are
encouraged to compare their E6 Portfolios’ statements with their brokerage account
statements provided by the custodian.
The E6 Portfolios Wrap Fee program sponsor bears the cost of all transactions that take place in
the client account, including trading
commissions, mutual fund ticket charges, clearance, and
any other transaction costs. Because E6 Portfolios bears transaction costs, the firm may have a
financial incentive to trade less frequently in Wrap Fee Program accounts than would be
beneficial to the client. Similarly, many custodians offer non-transaction fee funds or do not
charge commissions on ETF or equity trades. E6 Portfolios has an incentive to purchase these
investments for the client rather than investments that have a trading cost.
E6 Portfolios believes that its Wrap Fee Program fees are reasonable but the firm’s fees may be
more than the cost of purchasing comparable services separately or through other advisors.
Relative cost would depend on many factors including the cost of each service if provided
separately, the comparative volume of trading, value provided, and the cost of trading.
Clients bear the cost of management fees and other expenses imposed directly by mutual funds
or exchange traded funds held by the client; spreads paid to market makers; and any account
maintenance fees agreed to with the Custodian such as custodial, account, or wire fees.
E6 Portfolio fees are not negotiable but in some cases preexisting fee schedules may be
grandfathered in. Fees are waived for Employees and affiliates.
Because E6 Portfolios uses a related-person manager, all fees charged, net of expenses, are
paid to the portfolio managers.
Individuals recommending the wrap fee program do not receive additional compensation as a
result of the client’s participation in the program.
Margin Costs
The custodians recommended by E6 Portfolios can make margin borrowing available to clients.
E6 Portfolios does not recommend margin borrowing and does not incorporate margin
exposure into its strategies, however, E6 Portfolios may facilitate margin borrowing at the
client’s request. Margin borrowing incurs interest and other costs to the client that vary by
custodian and as interest rates change. E6 Portfolios does not bill on margin balances and does
not receive revenue from custodians related to margin borrowing and therefore has no
incentive to recommend margin.
Investment Discretion
E6 Portfolios’ clients grant the firm discretionary trading authority in the account(s) so that the
firm can implement the agreed-upon offering. Discretion includes the authority to make all
decisions to investigate, buy, sell, or hold securities, cash, or other publicly traded investments
on behalf of the client at E6 Portfolios’ sole discretion and without first consulting the client. In
their agreements with the qualified custodian, the client authorizes the custodian to follow E6
Portfolios’ instructions concerning trading and other investment activity in the account on
behalf of the client.
In cases where a client grants discretion, accounts that a client places under E6 Portfolios’
management will be liquidated and the proceeds reinvested in the Client’s chosen strategy.
Relationship with TomiPlan
E6 Portfolios believes that Clients are best served when they have a financial plan. E6 Portfolios
works with any qualified, credentialed financial planner selected by the client. Clients who do
not already have a financial planner will be referred to TomiPlan if they are in need of Financial
Planning services.
TomiPlan is an affiliated company under shared ownership with E6 Portfolios so we have an
incentive to recommend TomiPlan. E6 Portfolios also provides TomiPlan with investment data
aggregation capabilities used by licensed TomiPlan partners to assist their mutual clients with
financial planning services. E6 Portfolios mitigates this conflict of interest by prohibiting the
sharing to, or receiving of, revenue between E6 Portfolios and TomiPlan.
Relationship with Third-Party Investment Advisors
E6 Portfolios’ clients can authorize E6 Portfolios to accept instructions from the client’s third-
party investment advisor. This authorization is granted under a separate agreement. This third-
party investment advisor agreement instructs E6 Portfolios to accept instructions regarding Risk
Profile selection, changes in risk profile, cash movement, purchase or sale of investments, cash
management, and other account issues from the third-party investment advisor.
Communications from the third-party Investment Advisor contain significant decisions about
investment strategy, risk profile, E6 Portfolios offering selected (and therefore the fees paid).
Client agrees under separate agreement to inform E6 Portfolios of changes to the relationship
between Client and the third-party Investment Advisor and to provide E6 Portfolios with
accurate contact information and inform the firm of any changes to their contact information.
Termination
E6 Portfolios or the client can end the advisory relationship at any time without penalty or fee
by giving written notice to the other party. Clients should review their Advisory Agreement for
further details. Clients enter into relationships with the account custodian directly and should
review their agreement with the custodian for conditions related to terminating the agreement
(such as transfer-out fees).
Brokerage Practices
E6 Portfolios recommends Qualified Custodians including Altruist, Fidelity, Interactive Brokers,
and TradePMR to Clients based on quality of execution, reliability, impartiality, service,
capabilities, quality of technology, and reasonableness of cost in relation to comparable
broker/dealers. E6 Portfolios monitors broker/dealer compensation and evaluates whether it is
in the clients’ best interest to explore new custody options. E6 Portfolios does not accept direct
payments or soft dollar benefits from brokers. However, since E6 Portfolios pays differing
transaction fees and platform fees to different custodians, there is an incentive to recommend
the custodian that incurs the lowest cost to E6 Portfolios. which may not always be the lowest
cost for the client.
Qualified custodians provide E6 Portfolios and its clients access to institutional brokerage
services including a range of investment products, execution of securities transactions, and
custody of client assets. Some qualified custodians we work with provide automated investing,
rebalancing, tax-loss harvesting, and other investing functions. The investment products and
services available through institutional platforms include some to which clients might not
otherwise have access or that would require higher minimums by clients acting individually.
These services directly benefit clients or their account(s) and are made available on an
unsolicited basis and at no charge to us or the client.
Qualified custodians also make available other products and services that benefit E6 Portfolios
but may not directly benefit the client or their account(s) directly or at all. For example, the
custodian can provide research resources that can be used to improve service to all or some
client accounts, including accounts not maintained at the custodian providing the research.
Qualified custodians also provide software and other technology; support for third-party
service providers; trade aggregation for multiple client accounts; market data; and assistance
with back-office functions, recordkeeping, and client reporting.
Other services may help E6 Portfolios develop its business. These services might include
educational conferences and events; technology, compliance, legal, and business consulting;
publications and conferences on practice management; and access to employee benefits
providers, human capital consultants, and insurance providers. Custodians may provide some of
these services themselves or may arrange for third-party vendors to provide the services to E6
Portfolios at a discount or at no cost. These services are not contingent on E6 Portfolios
committing any specific amount of business to the custodian in trading commissions or assets
in custody, nor are they based on E6 Portfolios giving any particular investment advice or
buying particular securities for clients. Access to resources that do not directly benefit clients
may play a part in E6 Portfolios’ choice of custodians. E6 Portfolios addresses this conflict of
interest by carefully vetting its custodians based on their ability to assist in E6 Portfolios in
delivering the best value and experience and providing clients a range of custodial options.
E6 Portfolios does not receive client referrals from its qualified custodians and the firm does
not allow directed brokerage.
Clients can request an alternative broker/dealer for custody of their assets. However, the
alternative custodian may not approve E6 Portfolios on their platform, E6 Portfolios may not be
able to implement a specific Investment Strategist on that platform, and E6 Portfolios will
consider relationship size before agreeing to work with the additional custodian.
E6 Portfolios aggregates client trades on a best-efforts basis. A significant portion of client
assets are invested in mutual funds which are not vulnerable to trading conflicts of interest.
Client assets may also be invested in ETFs or individual securities. These transactions are
generally small in size relative to the daily volume in the security which minimizes any potential
inequities created by sequence of transaction. For Investment Strategists that rely on a
Qualified Custodian providing automated investing services, trade aggregation may be done at
the Custodial level but be out of E6 Portfolios’ control. Other circumstances inherently preclude
aggregation, such as client-directed liquidation or distribution of funds, new deposits arriving in
only one account, etc. These factors and aggregation practices mean that it is possible that one
client may receive less favorable execution than another in some cases.
However, E6 Portfolios does use aggregated trading whenever possible when the same ETF or
security is purchased or sold for more than one client at the same time. In cases where
aggregated trading is used, a target trade size and allocation among client accounts will be
established, the shares will be purchased or sold, an average price established, and the trade
allocated among client accounts at the established average price. If it is not possible to buy or
sell the planned number of shares, the partial trade will be allocated among clients
proportionally according to the planned allocation. In some cases, E6 Portfolios may make use
of aggregated trading for the same security more than once during a single trading day for
different groups of clients, resulting in different average prices for different groups of clients.
E6 Portfolios may enroll clients in custodial securities lending or yield enhancement programs
when available and shares all the revenue from these programs with the clients to enhance
returns. These programs may increase the number of shares available in the market for short-
selling. Clients must notify E6 Portfolios if they wish to opt-out of these services.