Description of Services and Fees
EP Wealth Advisors, LLC (also referred to as "EPWA" herein) is organized as a limited liability
company under the laws of the State of Delaware. EP Wealth Advisors, LLC, as organized today, has
been providing investment advisory services since 2004 but EPWA dates back to 1999 through a
predecessor firm that was established by EP’s Co-Founders Brian Parker and Derek Holman. EP
Wealth Advisors Holdings, LLC (“Hold Co.”) is the sole owner of our firm. The principal investors in
Hold Co. are EPWA Inc. and Project EPIC Acquisition LLC (“EPIC”)
We are a fee only independent investment adviser that provides wealth management services
through investment management, financial planning, tax preparation and other services. The
combination of our industry experience and research process allows our firm to provide quality
advisory services which are personalized to each individual client.
The following paragraphs describe our services and fees. Please refer to the description of each
investment advisory services listed below for information on how we tailor our advisory services to
your individual needs. Also, you may see the term Associated Person throughout this Brochure. As
used in this Brochure, our Associated Persons are our firm's officers, employees, and all individuals
providing investment advice on behalf of our firm.
Portfolio Management Services
We provide discretionary portfolio management services and under limited circumstances non-
discretionary portfolio management services tailored to meet the needs and investment objectives of
our clients. If you retain our firm for portfolio management services, we will discuss with you your
investment objectives, risk tolerance, and other relevant information (the "suitability information") at the
beginning of our advisory relationship and reviewed periodically thereafter or as deemed necessary
based on changes specific to each clients financial situations. We will use the suitability information we
gather to develop a strategy that enables our firm to give you continuous and focused investment
advice. As part of our portfolio management services, we may utilize an appropriate model portfolio
and/or we may customize an investment portfolio for you in accordance with your risk tolerance and
investing objectives. Once we construct an investment portfolio for you, we will monitor your portfolio
on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and
in your financial circumstances.
In some cases, we may recommend that clients invest in 529 college saving plans. We do not receive
any commissions from the 529 providers in connection with this recommendation; however, we may
provide portfolio management services for a fee as discussed below. Our portfolio management
services include reviews and reallocation of funds as necessary. We will typically recommend 529
college saving plan providers with which are affiliated and/or have a relationship with custodians which
we utilize or other providers with which we have a relationship. The providers we recommend provide
us with a platform that allows us to better serve the account and effectively manage the 529 college
savings plan. We believe that these companies offer 529 college saving plans that are competitive in
the market, however there is no assurance or warranty that these companies will be the most
profitable. There may be other companies that are better suited for your individual needs. You are
under no obligation to use the companies we recommend.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow our firm to
determine the specific securities, and the amount of securities, to be purchased or sold for your
account without your approval prior to each transaction. In certain circumstances, we may also
exercise discretion to select the broker-dealer to be used. Discretionary authority is typically granted
by the investment advisory agreement you sign with our firm or trading authorization forms. If you
enter into non-discretionary arrangements with our firm, we must obtain your approval prior to
executing any transactions on behalf of your account.
Upon your request, we may agree to provide advice on accounts which are not managed by our firm
(e.g. 401k and 403b accounts). Such advice will only be furnished on a periodic and non-continuous
basis. It will be your responsibility to act on any of the recommendations we provide and to initiate a
request for each review.
Description of Fees
The annual fee for portfolio management services is billed either quarterly in advance based on the
market value of the assets under management on the last day of the preceding calendar quarter, quarterly
in arrears (after the services have been provided) based on the market value of the assets under
management (as described in the investment advisory agreement) on the last day of the calendar quarter
or in limited circumstanced a combination of both. Fees billed quarterly in arrears are adjusted pro-rata for
contributions and withdrawals to the account. Fees billed quarterly in advance are not adjusted for
contributions or withdrawals to the account.
Fees will be assessed pro rata in the event the investment advisory agreement is executed at any time
other than the first day of a calendar quarter. Our standard fee is based on a percentage of assets under
management. The fees to Non-Discretionary Accounts will be higher than the fees charged to
Discretionary client relationships. Clients are assigned varying fee schedules and under any of the
following fee structures: a percentage of assets under management fee both in a blended tiered structure,
a tiered flat percentage fee structure (cliff tiered structure) or a flat percentage based fee, an annual fee, a
minimum quarterly or upfront fee, and/or any combination thereof As a result, some clients may pay a fee
that may be higher or lower than the above stated fee. For clients that originated from advisory firms that
EPWA purchased ("Purchased Clients"), in an effort to keep fees unchanged for Purchased Clients, to the
extent possible, EPWA will attempt to retain the fees that were assigned to the Purchased Clients by their
respective predecessor firm. In these instances, the fees assigned to Purchased Clients were negotiated
by the predecessor adviser and honored by EPWA. However, our fees are negotiable based upon a
variety of factors including, but not limited to, the size of relationship, services offered and complexity of
the relationship. In all cases, a client's assigned fee will be specified in the Investment Advisory
Agreement that will be signed prior to the commencement of the working relationship with our firm.
At our discretion, we may combine the account values of family members to determine the applicable
advisory fee. For example, we may combine account values for you and your minor children, joint
accounts with your spouse, and other types of related accounts. Combining account values may increase
the asset total, which may result in you paying a reduced advisory fee based on the available breakpoints
in the fee schedule stated above.
We will send you an invoice for the payment of our advisory fee, or we will deduct our fee directly from
your account through the qualified custodian holding your funds and securities. We will deduct our
advisory fee only when you have given our firm written authorization permitting the fees to be paid
directly from your account. Further, the qualified custodian will deliver an account statement to you at
least quarterly. These account statements will show all disbursements from your account. You should
review all statements for accuracy.
You may terminate the investment advisory agreement upon written notice to our firm. You will incur a
pro rata charge for services rendered prior to the termination of the agreement, which means you will
incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If
you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of
those fees.
Wrap Fee Programs
EPWA sponsors the EPWA Wrap Fee Program. The EPWA Wrap Fee Program will be offered to
clients at EPWA’s discretion and in limited circumstances. This program is one under which specified
fees that include securities transaction fees for certain mutual funds, custodial costs, administrative
fees and trade-away fees (herein “Covered Costs”) are combined together with the client’s investment
advisory fees. As such, these fees are consolidated into a single asset-based fee. This arrangement
is considered a “Wrap Fee”. EPWA customizes its investment management services for its Clients.
However, there is no material difference to services offered or investment advice that is different or
unique to clients of the EPWA Wrap Fee Program. As a sponsors of the EP Wealth Advisors Wrap
Fee Program, EPWA has prepared a supplemental disclosure document (“Wrap Fee Program
Brochure”) that details the services, fees, and conflicts of The EPWA Wrap Fee Program. Depending
on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more
or less in total fees than if the Client paid its own transaction fees. Additionally, because of the
consolidation of fees, the fee schedule assigned to wrap fee clients are usually higher than the typical
asset-based advisory fee assigned to clients that are not EPWA Wrap Fee Program clients. Appendix
1 – Wrap Fee Program Brochure, will always be included as a supplement to this Disclosure Brochure
for any Client or Perspective Client of the EPWA Wrap Fee Program or upon request for all other
Clients or Perspective Clients of EPWA.
Financial Planning and Consulting Services
If you retain our firm for portfolio management services, we will provide some financial planning and
consulting services. These services may address subjects, including but not limited to, cash flow, wealth
management/transfer strategies, estate planning, risk assessment, executive benefits and business
succession/planning, children's education, 1031 tax exchanges, real estate/mortgages and retirement
planning, family planning, insurance, tax planning, and investments. If you wish to receive, additional
financial planning services or your needs are considerable, we will notify you, in writing, and offer these
services at an hourly rate of up to $250. In such event, we will provide you with a copy of our Hourly
Financial Planning Agreement. You are under no obligation to sign the agreement or proceed with these
services.
You may, however, retain our firm for hourly or retainer based financial planning and consulting services
only. In such cases, we will gather information about your financial circumstances, objectives and other
relevant data. Once such information has been reviewed and analyzed, a written financial plan may be
produced and presented to you and/or we may provide consultations with general or specific
recommendations, which may be given orally.
Financial plans are based on your financial situation at the time we present the plan to you, and on the
financial information you provide to our firm. You should also be aware that our financial plans may
contain certain assumptions with respect to interest and inflation rates, along with past trends and
performance of the market and economy. Past performance is in no way an indication of future
performance. You must promptly notify our firm if your financial situation, goals, objectives, or needs
change.
If you hire our firm for hourly or retainer based financial planning financial planning and consulting
services only, we will charge an hourly fee of up to $250/hr payable monthly in arrears or a $2,500
retainer fee. Clients agree to make each payment upon receipt of an invoice from EPWA.
You may terminate the financial planning agreement upon written notice to our firm. You will incur
a charge for services rendered prior to the termination of the agreement based on our hourly rate.
In our sole discretion, we may waive or offset hourly financial planning fees. This decision may be based on
such factors as the scope and complexity of the services provided, whether the client has met our
general account minimum and/or whether you choose to implement the advice through our portfolio
management services as described above. You are under no obligation to act on our financial planning
recommendations. Should you choose to act on any of our recommendations, you are not obligated to
implement the financial plan through our portfolio management services.
Tax Preparation Service
Our firm offers tax preparation and filing services for clients with at least $1 Million in Assets Under
Management. If you choose to engage us for tax preparation services, you will enter into a separate
agreement and may pay a separate fee in addition to the fees paid to EP Wealth Advisors
for
investment advisory services. At our discretion, subject to client investment management asset levels,
we may choose to waive part or all of the fee for this specific service. The Tax Preparation Agreement
will detail the scope of services offered, conditions, termination provisions and the fees that will be
charged, if any. Clients who are offered this service are under no obligation to engage us in this
service. If authorized by you, our firm will work to facilitate documents and relevant information to/with
the Tax Professional or CPA of your choosing.
Estate Planning Services
For clients with at least $1 Million in Assets Under Management our Firm offers clients the ability to
obtain estate planning document preparation legal services through our professional partnership with
numerous independent attorneys and/or law firms. The services of EP Wealth Advisors and that of the
attorney or law firm we may refer you to are separate and distinct from one another. Each entity will
require that their respective clients complete a separate agreement with its own compensation
arrangement detailing the distinct services that each will render. At our discretion, subject to client
investment management asset levels, we may choose to cover part or all of the fee for this specific
service Furthermore, there is no common ownership or revenue sharing between the two entities.
EP Wealth Private Trust Services
National Advisors Trust Company, FSB (“NATC”) Doing Business As (“DBA”) EP Wealth Private Trust
can provide trust services to our clients. NATC is a federally chartered trust company regulated by the
Office of the Comptroller of the Currency and is a member of the Federal Deposit Insurance
Corporation. NATC and any of its subsidiary businesses including any of its DBAs, is an independent
entity and in no way under common ownership, control or otherwise affiliated with EPWA). Clients of
EPWA will be referred to NATC DBA EP Wealth Private Trust if it is believed that the Trust Services
offered by this entity can be of value to clients of EPWA. These clients will meet with NATC DBA EP
Wealth Private Trust and would be presented with their service agreement. Clients of EPWA would
independently review NATC’s Service Agreement and determine if they would like to engage them for
their Trustee Services. EPWA is not a Trust Company and is not in the business of delivering Trustee
Services to any of its clients.
We may recommend the services of other trust companies. The client is under no obligation to engage
the services of any recommended trust company. We do not receive any compensation (direct or
indirect) from any trust company for these referrals. The terms and conditions of a client’s engagement
with the trust company, including the fee payable by the client, are outlined in a separate agreement
between the client and the trust company.
Services Available to International Clients
At our discretion, we can offer investment management services to international clients and American
Expatriates clients living abroad (“Collectively referred as Foreign Clients”) if they meet the following
conditions:
• They must be eligible to open an account with one of our preferred custodians or a custodian
we deem acceptable; and
• They are not listed as an individual(s) as a blocked individual in the Office of Foreign Asset
Control (“OFAC”) or do not reside in a country, which is listed on the OFAC blocked country
list.
Furthermore, as a firm, we are not familiar, nor do we claim any level of understanding or expertise
with foreign Investment Laws, Tax Laws and/or any foreign government investment restrictions and/or
tax implications. For this reason, if an International Client files his/her/their taxes outside of the United
States, we will be required to advise and disclose the following:
• International Clients should consult a Tax Professional and Attorney in the Jurisdiction they
reside and file taxes to understand the tax consequences, investment limitations, and/or
investment restrictions that they may be subject to;
• Depending on the Custodian’s respective policy and restrictions, a client living outside of the
United States of America may not be eligible to invest in Mutual Funds or other securities;
• We may be unable to provide them with any Financial Planning services.
As a fiduciary, we owe our clients and prospective clients the duty to reiterate the aforementioned
information to allow them the opportunity to make an informed decision.
Retirement Plan Advisory Services
Our firm also provides advisory services to retirement plans subject to the Employee Retirement
Income Security Act of 1974 ("ERISA"), including participant-directed defined contribution plans, such
as 401(k) plans, defined contribution plans that are not participant-directed and defined benefit plans
("ERISA Plan Clients"). Each ERISA Plan Client is required to enter into an investment advisory or
management agreement with the firm describing the services that the firm will perform for the ERISA
plan and its participants. Our firm provides both ERISA fiduciary services and non-fiduciary services to
ERISA Plan Clients.
Fiduciary Services to Participant-Directed Defined Contribution Plans
For participant-directed defined contribution plans, our firm's fiduciary services include assisting the
ERISA Plan Client in selecting a broad range of investment options consistent with ERISA Section
404(c); assisting the ERISA Plan Client in making decisions about the selection, retention, removal and
addition of investment options; assisting the ERISA Plan Client in developing and implementing an
investment policy statement; and if the ERISA Plan Client has determined that the plan should have a
qualified default investment alternative (a "QDIA") for participants who fail to make an investment
election, assisting in the selection of the investment that will serve as a QDIA. Our firm provides these
fiduciary services on a non-discretionary basis and on a discretionary basis. If a client elects the non-
discretionary option, the ERISA Plan Client retains, and exercises, final decision-making authority and
responsibility for the implementation (or rejection) of our recommendations or advice. If the client elects
the discretionary option, we will be authorized and responsible for implementing changes to the plan's
mutual fund lineup by directly contacting the record-keeper.
Fiduciary Services to Defined Contribution Plans that are not Participant-Directed and Defined Benefit
Plans
For defined contribution plans that are not participant-directed and defined benefit plans, our firm's
fiduciary services include developing and implementing an investment policy statement, developing the
asset allocation and portfolio modeling, identifying and selecting specific investments to populate the
asset allocation categories, providing periodic re-balancing as deemed appropriate; and adding,
removing and/or modifying the underlying investments that populate the asset allocation categories.
Our firm provides these fiduciary services on a discretionary basis as an investment manager under
ERISA Section 3(38) and in that capacity, our firm's investment decisions are made in its sole
discretion without the ERISA Plan Client's prior approval.
Non-Fiduciary Services to ERISA Plan Clients
Our firm's non-fiduciary services to ERISA Plan Clients include, in the case of participant-directed
plans, assisting in group enrollment meetings and educating plan participants about general
investment principles and the investment alternatives under the plan.
For a more detailed description of our firm's fiduciary and non-fiduciary services, the ERISA Plan Client
should refer to the investment advisory agreement or investment management agreement, as the case
maybe.
For participant- directed plans we charge an annual fee of up to 1.00% of the market value of included
plan assets, as reported by the plan custodian or record-keeper. Included plan assets are the plan
assets for which our firm provides services as described in the investment advisory or management
agreement. Participant-directed plan services may be billed monthly in arrears or other fee-paying
arrangements may be made. For example, in some circumstances, fees may be billed quarterly and/or
in advance. You can pay the fee directly to us, authorization to deduct the fees can be granted to the
assigned Record-Keeper/Third Party Administrator, or we can deduct our fee from the plan's account
through the qualified custodian holding the plan's funds and securities.
For plans that are not participant-directed, fees are payable quarterly in arrears (the "Fee Period").
The initial fee is the amount, prorated for the number of days remaining in the initial Fee Period from
the effective date of the investment management agreement, based upon the market value of the
included assets on the last business day of the initial Fee Period. Thereafter, the fee is based upon the
market value of the included assets on the last business day of the Fee Period. Clients may be
assigned a flat percentage-based fee and/or a different fee schedule than the fees indicated above. As
a result, some clients may pay a fee that may be higher or lower than the above stated fees.
In either case, we will deduct our advisory fee only when you have given our firm written authorization
permitting the fees to be paid directly from the plan's account. A client's assigned fee will be specified
in the Advisory Agreement that will be signed prior to the commencement of the working relationship
with our firm. Furthermore, the qualified custodian will deliver an account statement to you at least
quarterly. These account statements will show all disbursements from the plan's account. You should
review all statements for accuracy.
You may terminate the advisory agreement upon written notice to our firm. The advisory fees will be
prorated for the quarter or month in which the termination notice is given.
Selection of Other Advisers
As part of our investment advisory services, we may recommend that you use the services of a third-
party investment adviser ("TPA") to manage a portion of your investment portfolio. After gathering
information about your financial situation and objectives, we may recommend that you engage a
specific TPA or investment program. Factors that we take into consideration when making our
recommendation(s) include, but are not limited to, the following: the TPA's performance, methods of
analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We
will monitor the TPA(s)' performance at least quarterly to ensure its management and investment style
remains aligned with your investment goals and objectives.
We include the assets managed by the TPA in calculating our advisory fee based on the fee schedule
stated above. In addition, the TPA will assess its own advisory fee. The advisory fee you pay the TPA
is separate and apart from the advisory fee paid to our firm. Our firm does not participate in any fee
sharing arrangement with any TPA nor do we receive any compensation for the referral of any TPA.
You may be required to sign an agreement directly with the recommended TPA(s). You may terminate
your advisory relationship with the TPA according to the terms of your agreement with the TPA. You
should review each TPA's disclosure brochure for specific information on how you may terminate your
advisory relationship with the TPA and how you may receive a refund, if applicable. You should contact
the TPA directly for questions regarding your advisory agreement with the TPA. In certain cases, and
with your written consent, we may have discretion to hire and fire the TPA and/or re-allocate assets
amongst TPAs on your behalf.
Types of Investments
We offer advice on investment company securities (mutual funds) and equity securities. We may also
advise you on exchange traded funds, corporate debt securities, commercial paper, certificates of
deposit, municipal securities, U.S. Government securities, Separate Account Managers, and Liquid
and Illiquid Alternative Investments.
Additionally, we may advise you on any type of investment that we deem appropriate based on your
stated goals and objectives. We may also provide advice on any type of investment held in your
portfolio at the inception of our advisory relationship. If suitable for a client's portfolio and if the client
meets the minimum requirements for investing, we may recommend and advise you on private funds,
hedge funds and other alternative investments.
You may request that we refrain from investing in particular securities or certain types of securities. You
must provide these restrictions to our firm in writing.
Assets Under Management
As of February 29, 2024, we manage $22,321,000,000in client assets of which $21,474,000,000is on
a discretionary basis, and $312,000,000 in client assets on a non-discretionary basis. is managed
through our Retirement Plan Advisory Services.