A. Investment Advisory Services
The client can determine to engage Shulman DeMeo Asset Management, LLC (“Shulman DeMeo”)
to provide discretionary and/or non-discretionary investment advisory services on a wrap fee basis.
If a client determines to engage Shulman DeMeo on a wrap fee basis the client will pay a single fee
for bundled services (i.e. investment advisory, brokerage, custody). The services included in a wrap
fee agreement will depend upon each client’s particular need.
As of December 31, 2022, Shulman DeMeo had $579,755,411 in regulatory assets under management, of
which $521,076,366 is managed on a discretionary basis and additional $58,679,045 is managed on a non-
discretionary basis.
Shulman DeMeo Asset Management, LLC Wrap Program
Shulman DeMeo provides investment management services on a wrap fee basis in accordance with
Shulman DeMeo’s investment management wrap fee program (the “Program”). Under the Program,
Shulman DeMeo is able to offer participants discretionary and/or non-discretionary investment
management services, for a single specified annual Program fee, inclusive of trade execution,
custody, reporting, and investment management fees. The terms and conditions for client
participation in the Program are set forth in detail in this Wrap Fee Program Brochure, which is
presented to all prospective Program participants in accordance with the disclosure requirements of
Part 2A Appendix 1 of Form ADV. All prospective Program participants should read both Shulman
DeMeo’s Informational Brochure and the Wrap Fee Program Brochure and ask any corresponding
questions prior to participation in the Program.
Wrap Program-Conflict of Interest. When managing a client’s account on a wrap fee basis,
Shulman DeMeo shall receive as payment for its investment advisory services, the balance of the
wrap fee after all other costs incorporated into the wrap fee have been deducted. Participation in a
wrap program has a cost to the client that can be more or less than purchasing such services
separately. For example, if a client’s account is rarely traded, the transaction fees the client would
have paid would be minimal, thus limiting the benefits of “wrapping” management fees and
transaction fees. The terms and conditions of a wrap program engagement are more fully discussed
in this Wrap Fee Program Brochure. Because wrap program transaction fees and/or commissions
are being paid by Shulman DeMeo to the account broker-dealer/custodian, Shulman DeMeo could
have an economic incentive to minimize the number of trades in the client’s account. This presents
a conflict of interest. Shulman DeMeo attempts to mitigate this conflict by disclosing the conflict
to clients and requiring that the firm’s employees acknowledge their fiduciary duty to place client
interests ahead of their own.
Schwab’s Brokerage Services
In addition to the foregoing portfolio management and other services, the Program includes the
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. Shulman DeMeo is an
independently owned and operated and not affiliated with Schwab. Schwab will act solely as
custodian and broker-dealer and not as an investment advisor to you. It will have no discretion over
your account and will act solely on 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 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. While
we require that you use Schwab as custodian/broker to participate in our program, you will decide
whether to do so and open your account with Schwab by entering into an account agreement directly
with them. We do not open the account for you. If you do not wish to place your assets with Schwab,
then we cannot manage your account in the program. Not all advisors require their clients to use a
particular broker-dealer or other custodian selected by the advisor. Even though your account is
maintained at Schwab, we can still use other brokers to execute trades for your account, as described
below.
B. Shulman DeMeo Asset Management, LLC Wrap Program Fees
Under the Program, Shulman DeMeo is able to offer participants discretionary and/or 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 ranges from 0.00% to 2.00%.
Shulman
DeMeo’s annual investment advisory fee shall include investment advisory services, and,
to the extent specifically requested by the client, financial planning and consulting services. In the
event that the client requires extraordinary planning and/or consultation services (to be determined
in the sole discretion of Shulman DeMeo), Shulman DeMeo will, where applicable, determine to
charge for such additional services, of which the dollar amount and method of payment shall be set
forth in a separate written notice to the client.
Fee Payment. Clients that elect to have Shulman DeMeo’s advisory fees deducted from their
custodial account. Both Shulman DeMeo’s Agreement and the custodial/clearing agreement that
authorizes the custodian to debit the account for the amount of Shulman DeMeo’s investment
advisory fee and to directly remit that management fee to Shulman DeMeo in compliance with
regulatory procedures. In the limited event that Shulman DeMeo bills the client directly, payment
is due upon receipt of Shulman DeMeo’s invoice. Shulman DeMeo shall deduct fees and/or bill
clients quarterly in advance, based upon the market value of the assets on the last business day of
the previous quarter. For example, if your annual fee is 1.50%, each quarter Shulman DeMeo will
multiply the value of the accounts on the last business day of the previous quarter by 1.50%, then
divide by four to calculate our quarterly fee. To the extent there is cash in your account, it will be
included in the value for the purpose of calculating fees only if the cash is part of an investment
strategy.
Other Fees. As discussed above, unless the client directs otherwise or an individual client’s
circumstances require, Shulman DeMeo requires that Schwab serve as the broker- dealer/custodian
for client investment management assets under the Program. The Program’s wrap fee does not
include certain charges and administrative fees, including, but not limited to, relative to all mutual
fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees
and other fund expenses), transaction charges (including mark-ups and mark-downs) resulting from
trades effected through or with a broker-dealer other than Schwab, 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’s wrap fee.
Pro-rata Fees. If you become a client during a billing period, you will pay an
investment advisory fee based upon the number of days left in that billing quarter.
The Agreement between Shulman DeMeo and the client will continue in effect until
terminated by either party by written notice in accordance with the terms of the
Agreement. Upon termination, Shulman DeMeo shall refund the pro-rated portion
of the advanced advisory fee paid based upon the number of days remaining in the
billing quarter.
C. Additional Fees for Stand-Alone Services
FINANCIAL PLANNING AND CONSULTING SERVICES FEES (STAND-ALONE)
For client’s engaging Shulman DeMeo for stand-alone financial planning and
consulting services, fees are negotiable, but generally range from $5,000 to $50,000
on a fixed fee basis, and from
$300 to $700 on an hourly rate basis, depending upon the level and scope of the
service(s) required and the professional(s) rendering the service(s).
PORTFOLIO MONITORING SERVICES
For clients who wish to also engage Shulman DeMeo for a portfolio monitoring
service, such clients that engage Shulman DeMeo to monitor client portfolios or
investments held with other independent registered investment advisers. The current
annual fee for portfolio monitoring
services are up to 2.00% of the client’s assets under management.
Shulman DeMeo is limited, however, to performing our portfolio monitoring services
and/or making recommendations for certain portfolios held at other RIAs including
401(k) Plans in which the available investment options are determined by the plan
sponsor, 529 Plans, etc. Portfolio monitoring services performed by Shulman DeMeo do
present conflicts of interest including the possibility that recommended portfolio changes
more aligned with our Firm’s investment approach and strategies potentially conflict with
the investment advice furnished by the other RIAs. In addition, the transition costs for
replacing or liquidation of certain securities at other RIAs will cause additional costs, at
least in the short term, for the investor.