We are the sponsor of the Kiplinger Wealth Advisors wrap fee program. Our wrap fee program
allows you to pay a single fee that covers advisory services, trade execution, custody and other
standard brokerage services. As of February 8, 2024, we manage $189,133,302 in discretionary
assets.
ASSET MANAGEMENT SERVICES
Our asset management services are provided on a discretionary or non-discretionary basis to
assist with the ongoing management of your investment accounts. We work with you to
understand your investment objectives, time frame and risk tolerance. With this information,
we will create a customized portfolio using a combination of our model portfolios. We base our
recommendations on a variety of factors including but not limited to performance, risk, tax
efficiency of different investment strategies as well as your input and preferences regarding the
strategies.
USE OF SUB-ADVISERS
When deemed appropriate, we recommend the services of a Sub-adviser to manage some or all
of your assets on a discretionary basis. In these situations, we provide consulting and advisory
services in overseeing such sub-advisers. We make recommendations regarding the use of a Sub-
adviser and their investment style based on, but not limited to, your financial needs, long-term
goals, and investment objectives.
The sub-adviser offers multiple model portfolios. Once a Sub-adviser is selected, we continue to
monitor them to ensure that they adhere to the philosophy and investment style for which they
were selected. We will retain discretionary authority to hire and fire the sub-adviser and, when
necessary, reallocate your assets to a new sub-adviser. A complete description of the Sub-
adviser’s services and fees will be disclosed in the sub-adviser’s Form ADV Part 2A or equivalent
brochure which will be provided to you.
PARTICIPANT ACCOUNT MANAGEMENT (DISCRETIONARY)
As part of our Investment Management Services, we use a third-party platform to facilitate
management of held away assets such as defined contribution plan participant accounts, with
discretion. The platform allows us to avoid being considered to have custody of client funds since
we do not have direct access to client log-in credentials to affect trades. We are not affiliated with
the platform in any way and receive no compensation from them for using their platform. A link will
be provided to the client allowing them to connect an account(s) to the platform. Once client
account(s) is connected to the platform, we will review the current account allocations. When
deemed necessary, we will rebalance the account considering client investment goals and risk
tolerance, and any change in allocations will consider current economic and market trends. The
goal is to improve the account performance over time, minimize loss during difficult markets, and
manage internal fees that harm account performance. Client account(s) will be reviewed at least
quarterly, and allocation changes will be made as deemed necessary.
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FEES
We charge a single asset-based fee for services covered by the wrap program. The annual asset-
based management fee ranges from 0.70% to 2.00% and is negotiable. The exact fee or fee
schedule charged is disclosed to you prior to services being provided. We may “bundle” related
accounts to achieve a break on management fees. Account bundling can be done only on
accounts with the same fee schedule and with clients in the same immediate family or under
the same qualified plan. When accounts are bundled monthly custodian reported account
balances for all bundled accounts is used to determine the fee percentage from the fee
schedule. The percentage is then applied to each account and a fee is charged to each
respectively. Certain clients may be billed based on previous retired fee schedules.
Typically, management fees are automatically deducted from your account according to an
authorization provided in the client agreement. On an exception basis, you may have
management fees paid from other accounts or have us bill you directly by invoice. In such cases,
the management fee is noted as zero on your custodial statements.
Management fees are billed monthly in advance except for the initial fee. The initial fee is billed
in arrears, prorated based on the number of days those services were provided during the first
billing period. This initial fee is billed at the same time the first full period fee is billed in advance.
Management fees are calculated at the beginning of each calendar month based on the
custodian reported account value as of the last business day of the previous month. The fee
calculation does not take into account unpriced securities held in the account or days when the
account has a zero balance.
We will ask you to authorize us with the ability to instruct the custodian to directly deduct our
management fee from your account. You may cancel this authorization at any time. Please Item
15 – Custody for additional details regarding fee deduction.
Our management fee includes some custodian fees. Altruist Financial LLC, an unaffiliated SEC-
registered broker dealer and FINRA/SIPC member, a recommended custodian, charges a monthly
fee of $1 per account. We pay that fee for our clients. The client may incur other charges imposed
by the custodian such as wire transfer and electronic fund fees, and other fees and taxes on
brokerage accounts and securities transactions. Mutual funds and exchange traded funds also
charge internal management fees, which are disclosed in a fund’s prospectus. These charges,
fees, and commissions are exclusive of and in addition to our fee and we do not receive any
portion of these charges, fees, or commissions. Please see Item 12 – Brokerage Practices for
additional information.
In addition to the advisory services and Altruist Financial LLC, the wrap fee program also includes
certain brokerage services of Charles Schwab & Co., Inc., (“Schwab”) a broker-dealer registered with
the Securities and Exchange Commission and a member of FINRA and SIPC. We are independently
owned and operated and not affiliated with Schwab. Schwab will act solely as a broker-dealer and
not an investment adviser to you. It will have no discretion over your account and will act solely on
the instructions it receives from us or you. Schwab has no responsibility for our services and
undertakes no duty to you to monitor our management of your account or other services we provide
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to you. Schwab will hold your assets in a brokerage account and buy and sell securities and execute
other transactions when we or you instruct them to. We do not open an account for you.
In a wrap account, clients pay a single annual advisory fee for advisory services and execution of
transactions. Clients do not pay brokerage commissions, markups or transaction charges for
execution of transactions in addition to the advisory fee.
TERMINATION OF PORTFOLIO MANAGEMENT SERVICES
Any services may
be terminated at any time, for any reason, by either of us. Services provided
under the Agreement will continue until either you or we give written notice of termination to
the other party. Termination is effective upon receipt of notice, although transactions in progress
will be completed in the normal course of business. If we receive a request to terminate and
liquidate your account, we have up to 72 hours to begin liquidating. Upon termination any
prepaid, unearned management fees will be calculated and promptly refunded based upon the
number of days remaining in the billing period after the termination date. Fees owed will be
promptly deducted from the account or will be invoiced accordingly if there are no assets in the
account. Subsequent transactions in a closed account are subject to our broker/dealer affiliate’s
normal brokerage rates and commissions. For general information as to how fees are assessed,
please refer to the specific program listed in the section titled “Fees.” For financial planning fees
paid in advance will be refunded on a prorated basis based on the time and effort expended by
us prior to receipt of the notice of termination. If no fees are paid in advance, you will be
responsible for payment upon receipt of a bill from our firm.
OTHER TYPES OF FEES AND CHARGES
Program accounts may incur additional fees and charges from parties other than us as noted
below. These fees and charges are in addition to the normal advisory fees.
Charles Schwab & Co., Inc. (“Schwab”) a broker-dealer registered with the Securities and
Exchange Commission and a member of FINRA and SIPC and Altruist Financial LLC, an unaffiliated
SEC-registered broker dealer and FINRA/SIPC member, as the introducing broker to Apex Clearing
Corporation, an unaffiliated SEC registered broker dealer and FINRA/SIPC member, act as the
custodians and broker-dealers providing brokerage and execution services on program accounts,
will impose certain fees and charges. The client is notified of these charges at account opening
and we can provide a copy at the client’s request.
There are other fees and charges that are imposed by other third parties that apply to
investments in program accounts. Some of these fees and charges are described below:
• In addition to compensating us for advisory services, the wrap fee you pay us allows us to
pay for brokerage and execution services provided by Schwab. We pay Schwab transaction
costs for each executed trade in wrap fee accounts. As a result, we have a financial incentive
to limit orders for wrap fee accounts because trades increase our transaction costs. Thus, an
incentive exists to trade less frequently in a wrap program.
• If a client’s assets are invested in mutual funds or other pooled investment products, clients
should be aware that there will be two layers of advisory fees and expenses for those assets.
Client will pay an advisory fee to the fund manager and other expenses as a shareholder of
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the fund. Client will also pay us the advisory fee with respect to those assets. Most of the
mutual funds available in the program may be purchased directly. Therefore, clients could
generally avoid the second layer of fees by not using our management services and by making
their own investment decisions.
• If client holds a variable annuity as part of an account, there are mortality, expense and
administrative charges, fees for additional riders on the contract and charges for excessive
transfers within a calendar year imposed by the variable annuity sponsor.
Further information regarding fees assessed by a mutual fund, or variable annuity is available in
the appropriate prospectus, which is available upon request from us or from the product sponsor
directly.
OTHER IMPORTANT CONSIDERATIONS
• A Wrap fee is no based directly on the number of transactions in your account. Various factors
influence the relative cost of our wrap fee program to you, including the cost of our
investment advice, custody, and brokerage services if you purchased them separately, the
type of investments held in your account, and the frequency, type and size of trades in your
account. The program cost you more or less then purchasing our investment advice and
custody/brokerage services separately.
• The advisory fee is an ongoing wrap fee for investment advisory services, the execution of
transactions and other administrative and custodial services. The advisory fee may cost the
client more than purchasing the program services separately, because the client could pay an
advisory fee plus commissions for each transaction in the account. Factors that bear upon the
cost of the account in relation to the cost of the same services purchased separately include
the type and size of the account, historical or expected size or number of trades for the
account, and number and range of supplementary advisory and client-related services
provided to the client.
• The advisory fee also may cost the client more than if assets were held in a traditional
brokerage account. In a brokerage account, a client is charged a commission for each
transaction, and the representative has no duty to provide ongoing advice with respect to the
account. If the client plans to follow a buy and hold strategy for the account or does not wish
to purchase ongoing investment advice or management services, the client should consider
opening a brokerage account rather than a program account.
The investment products available to be purchased in the program can be purchased by clients
outside of a program account, through broker-dealers or other investment firms not affiliated
with us.
FEES AND COSTS NOT INCLUDED
Our wrap fee covers our advisory services and the brokerage services provided by Schwab
including custody of assets, equity trades, ETFs, and agency transactions in fixed income
securities. As a result, we have incentive to execute transactions for your account at Schwab.
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Our wrap fee does not cover all fees and costs. The fees not included in the wrap fee include
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 expenses), mark-ups
and mark-downs, spread paid to market makers, fees (such as commission or markup) for trades
executed away from the custodian at another broker-dealer, wire transfer fees and other fees
and taxes on brokerage accounts and securities transactions.
RETIREMENT ROLLOVER CONFLICTS OF INTEREST
When we recommend you rollover a retirement account for us to manage, this creates a financial
incentive because we charge a fee for our services. We attempt to mitigate the conflict of interest
by acting in your best interest and applying an impartial conduct standard to all rollovers. Please
note that you are not under any obligation to roll over a retirement account to an account
managed by us.