A.
CJM ASSET MANAGEMENT WRAP PROGRAM
Program Overview: CJM Wealth Advisers, Ltd. (the “Registrant”) is the sponsor and
investment manager of the CJM Asset Management Wrap Program (hereinafter the
“Program”). Under the Program, the Registrant is able to offer participants discretionary
and non-discretionary investment management services, for a single specified annual
Program fee, inclusive of trade execution, custody, reporting, and investment management
fees. The current annual Program fee is generally 1.00% but may be reduced in the sole
discretion of Registrant.
Pershing, LLC (“Pershing”) shall serve as the custodian for Program accounts.
Program Fees: Clients will be charged in advance at the beginning of each calendar
quarter based upon the value (market value or fair market value in the absence of market
value, plus any credit balance or minus any debit balance), of the client's account at the end
of the previous quarter. For accounts opened during the quarter and for deposits or
withdrawals in amounts of $200,000 or more, fees are prorated and clients will pay the
additional amount or receive a credit in the following quarter.
The fee charged is calculated as described above and is not charged on the basis of a share
of capital gains upon or capital appreciation of the funds or any portion of the funds of an
advisory client, pursuant to Section 205(a)(1) of the Investment Advisers Act of 1940, as
amended (hereinafter the “Act”).
Participation in the Program may cost more or less than purchasing the Program’s services
separately from another investment adviser. The Program fee charged by Registrant for
participation in the Program may be higher or lower than those charged by other sponsors
of comparable wrap fee programs
The transaction fees and commissions incurred in client’s accounts are paid by the
Registrant to Pershing. Therefore, the Registrant has an economic incentive to minimize
the number of trades in the client’s account. This arrangement creates a conflict of interest.
In addition, Registrant may invest client assets through the Program in various mutual
funds available through the “Pershing Advisor Source” (“PAS”) platform. Through PAS,
Registrant may acquire certain mutual funds with no transaction fees (“NTF Funds”);
however, other mutual funds can only be acquired if Registrant pays a $10 transaction fee
(“TF Funds”). This creates a conflict of interest because Registrant has an economic
incentive under the Program to acquire NTF Funds over TF Funds because it is paying
transaction costs. The Registrant maintains a list of mutual funds that it uses to build client
portfolios, and as of February 17, 2021, less than one third of the funds on this list are NTF
Funds. These funds are widely used in creating client portfolios, and a client’s portfolio
can be up to 100% NTF Funds. To help mitigate this conflict of interest, clients may, at
any time restrict Registrant’s use of NTF Funds, in writing. Registrant will provide a list
of available NTF Funds and related information upon request. The Registrant’s Chief
Compliance Officer, Tracey A. Baker, CFP®, remains available to address any questions
that a client or prospective client may have regarding these conflicts of interest.
Fee Dispersion:
The Registrant’s investment advisory fee is negotiable at Registrant’s
discretion, depending upon objective and subjective factors including but not limited to:
the amount of assets to be managed; portfolio composition; the scope and complexity of
the engagement; the anticipated number of meetings and servicing needs; related accounts;
future earning capacity; anticipated future additional assets; the professional(s) rendering
the service(s); prior relationships with the Registrant and/or its representatives, and
negotiations with the client. As a result of these factors, similarly situated clients could
pay different fees, the services to be provided by the Registrant to any particular client
could be available from other advisers at lower fees, and certain clients may have fees
different than those specifically set forth above.
Termination of Advisory Relationship: The Investment Advisory Agreement between
the Registrant and the client will continue in effect until terminated by either party by
written notice in accordance with the terms of the Investment Advisory Agreement. Upon
termination, the Registrant shall refund the pro-rated portion of the advanced advisory fee
paid based upon the number of days remaining in the billing quarter.
Investment Performance: As a condition to participating in the Program, the participant
must accept that past performance may not be indicative of future results, and understand
that the future performance of any specific investment or investment strategy (including
the investments and/or investment strategies purchased and/or undertaken by the
Registrant) may not: (1) achieve their intended objective; (2) be profitable; or, (3) equal
historical performance level(s) or any other performance level(s).
B. Participation in the Program may cost more or less than purchasing such services
separately. Also, the Program fee charged by Registrant for participation in the Program
may be higher or lower than those charged by other sponsors of comparable wrap fee
programs.
Depending upon the percentage wrap-fee charged by the Registrant, the amount of
portfolio activity in the client's account, and the value of custodial and other services
provided, the wrap fee may or may not exceed the aggregate cost of such services if they
were to be provided separately by another investment adviser
C. The Program’s wrap fee does not include certain charges and administrative fees,
including, but not limited to, fees charged by Independent Managers, transaction charges
(including mark-ups and mark-downs) resulting from trades effected through or with a
broker-dealer other than Pershing, transfer taxes, odd lot differentials, exchange fees,
interest charges, American Depository Receipt agency processing fees, and any charges,
taxes or other fees mandated by any federal, state or other applicable law or otherwise
agreed to with regard to client accounts. Such fees and expenses are in addition to the
Program fee.
D. Registrant’s related persons who recommend the CJM Asset Management Wrap Fee
Program to clients do not directly receive compensation as a result of a client’s
participation in the wrap fee program. However, certain of the Registrant’s equity owners
receive the benefits indirectly.