Our firm manages assets for many different types of clients to help meet their financial goals while
remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is our duty to always act in
the client’s best interest. This is accomplished in part by knowing the client. Our firm has established
a service-oriented advisory practice with open lines of communication. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Our firm sponsors and offers a wrap fee program, which allows clients to pay a single fee for
investment advisory services and associated custodial transaction costs. Transaction fees will be paid
by our firm based on a percentage of the dollar amount of assets in the account(s) or via individual
transaction charges. Because our firm absorbs client transaction fees, an incentive exists to limit
trading activities in client accounts. Custodial transaction costs, however, are not included in the
advisory fee charged by our firm for non-wrap services, and are to be paid by the client to their
chosen custodian. Depending on the client’s account or portfolio trading activity, clients may pay
more for using our wrap fee services than they would for using our non-wrap services.
Our recommended custodians do not charge transaction fees for U.S. listed equities and exchange
traded funds. Additionally, through our relationship with Cambridge Research Inc., your assets may
be custodied at National Financial Services LLC and Fidelity Brokerage Services (collectively
“Fidelity”) which eliminated transaction fees for U.S. listed equities and exchange traded funds for
clients who opt into electronic delivery of statements or maintain at least $1 million in assets at
Fidelity. Since we pay the transaction fees charged by the custodian to clients participating in our
wrap fee program, this presents a conflict of interest because we are incentivized to recommend
equities and exchange traded funds over other types of securities in order to reduce our costs.
Our Wrap Advisory Services
Cooper McManus Wrap Asset Management:
As part of our Cooper McManus Wrap Asset Management service, a portfolio is created, consisting of
individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and
private securities or investments. The client’s individual investment strategy is tailored to their specific
needs and may include some or all of the previously mentioned securities. Portfolios will be designed to
meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the
appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if
necessary, rebalanced based upon the client’s individual needs, stated goals and objectives.
The maximum annual fee charged for this service will not exceed 2.10%. Fees to be assessed will
be outlined in the advisory agreement to be signed by the Client. Fees are negotiable and will be
deducted from client
account(s). Adjustments will be made for deposits that exceed $1,000. In
rare cases, our firm will agree to directly invoice. As part of this process, Clients understand the
following:
a) The client’s independent custodian sends statements at least quarterly showing the
market values for each security included in the Assets and all account disbursements,
including the amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms.
Our firm will send an invoice directly to the custodian; and
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 Cooper McManus
c) If our firm sends a copy of our invoice to the client, legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
When deemed suitable to the client our firm utilizes the sub-advisory services of third-party
investment advisory firms or individual advisors to aid in the implementation of an investment
portfolio designed by our firm. Before selecting a firm or individual, our firm will ensure that the
chosen party is properly licensed or registered.
For any sub-advisory services rendered to our clients, our firm typically compensates third party
investment advisory firms or individual advisors a percentage of the overall investment advisory fee
charged by our firm. If the fee is in addition to the fee charged by our firm, it shall be set forth in a
separate agreement between the client and the designated third party.
Other Types of Fees & Expenses:
In addition to our advisory fees above, clients may also pay holdings charges imposed by the chosen
custodian for certain investments, 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,
initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable
annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark-
downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer
fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not
receive a portion of these fees.
Termination and Refunds:
Either party may terminate the advisory agreement signed with our firm for Cooper McManus Wrap
Asset Management services in writing at any time. Upon notice of termination our firm will process
a pro-rata refund of the unearned portion of the advisory fees charged in advance or send a bill for
pro rata fees due in arrears.
Wrap Fee Program Recommendations:
In exchange for a percentage of the overall fee charged, our firm recommends the use of Cambridge
Research Inc.’s wrap services via the WealthPort Wrap Fee Program. This creates an incentive to
recommend client use of these services rather than a non-wrap program as our firm and the wrap
program’s sponsor may stand to earn higher fees if client accounts are not actively traded.