We offer wrap fee programs as described in this Wrap Fee Program Brochure. Our wrap fee
accounts are managed on an individualized basis according to the client’s investment objectives,
financial goals, risk tolerance, etc.
Our firm is the manager and sponsor to wrap programs that are offered to advisory clients on either
a discretionary or non-discretionary basis. The wrap programs charge a single fee based on a
percentage of assets under management that includes both portfolio management services and
execution costs associated with making trades. Our firm will provide clients with investment
recommendations and then enter the trade through a broker-dealer. After trades are executed for
clients, we pay the broker-dealer the execution cost associated with the trades.
We do not charge our clients higher advisory fees based on their trading activity, but you should be
aware that we may have an incentive to limit our trading activities in your account(s) because we are
charged for executed trades. By participating in a wrap fee program, you may end up paying more or
less than you would through a non-wrap fee program where a lower advisory fee is charged, but
trade execution costs are passed directly through to you by the executing broker. We also have the
capability to select investments with varying execution costs when making investment
recommendations to clients. The fact that we pay the execution costs for clients creates a conflict of
interest because our firm has a financial incentive to recommend investments to clients that have
lower execution costs in lieu of investments that have higher execution costs. Fidelity Brokerage
Services (“Fidelity”) 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. As a result, we are incentivized to recommend U.S. listed equities and exchange traded funds
over other types of securities in order to reduce our costs for qualifying clients.
Types of Wrap Advisory Services We Offer
Wrap Comprehensive Portfolio Management:
Our comprehensive portfolio management service encompasses asset management as well as
providing financial planning/financial consulting to clients. It is designed to assist clients in meeting
their financial goals through the use of financial investments. We conduct at least one, but
sometimes more than one meeting (in person if possible, otherwise via telephone conference) with
clients in order to understand their current financial situation, existing resources, financial goals,
and tolerance for risk. Based on what we learn, we propose an investment approach to the client.
We may propose an investment portfolio, consisting of exchange traded funds, mutual funds,
individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed
investment plan, we work with the client to establish or transfer investment accounts so that we
can manage the client’s portfolio. Once the relevant accounts are under our management, we review
such accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust
client accounts under our management. If the client experiences any significant changes to his/her
financial or personal circumstances, the client must notify us so that we can consider such
information in managing the client’s investments.
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 SCEWM
Fee Schedule
Assets Under Management Annual Percentage of Assets Charge
$0 to $499,999.99 1.50%
$500,000 to $1,000,000 1.25%
$1,000,000 to $2,999,999.99 1.00%
Over $3,000,000 Negotiable
Our firm’s fees are generally negotiable. Further, our firm’s fees are billed on a pro-rata annualized
basis quarterly in advance or in arrears based on the value of your account on the last day of the
(previous) quarter, as applicable. When calculating the advisory fee, we make adjustments for
deposits and withdrawals. In rare circumstances, we will agree to direct bill clients. In certain cases,
client may be charged a flat percentage for all assets under management of up to 1.50%. The exact
billing arrangement will be specified in the signed advisory agreement. As part of the process, you
understand and acknowledge the following:
(a) Your independent custodian sends statements at least quarterly to you, showing all
disbursements
on your account, including the amount of the advisory fees paid to us;
(b) You provide authorization permitting us to be directly paid by these terms;
(c) If we send a copy of our invoice to you, we send a copy of our invoice to the independent
custodian at the same time we end the invoice to you; and
(d) If we send a copy of our invoice to you, our invoice includes a disclosure that urges you to
compare the information provided in our statements with those from the qualified custodian.
Wrap Asset Management:
We emphasize continuous and regular account supervision. As part of our asset management service,
we generally create a portfolio, consisting of individual stocks or 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. Each portfolio will be initially designed to meet a particular investment goal,
which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been
determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based
upon the client’s individual needs, stated goals, and objectives.
Fee Schedule:
Assets Under Management Annual Percentage of Assets Charge
$0 to $499,999.99 1.25%
$500,000 to $1,000,000 1.00%
$1,000,000 to $2,999,999.99 0.75%
Over $3,000,000 Negotiable
Our firm’s fees are generally negotiable. Further, our firm’s fees are billed on a pro-rata annualized
basis quarterly in advance or in arears based on the value of your account on the last day of the
(previous) quarter, as applicable. When calculating the advisory fee, we make adjustments for
deposits and withdrawals. In rare circumstances, we will agree to direct bill clients. In certain cases,
client may be charged a flat percentage for all assets under management of up to 1.25%. The exact
billing arrangement will be specified in the signed advisory agreement. As part of the process, you
understand and acknowledge the following:
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 SCEWM
(a) Your independent custodian sends statements at least quarterly to you, showing all
disbursements on your account, including the amount of the advisory fees paid to us;
(b) You provide authorization permitting us to be directly paid by these terms;
(c) If we send a copy of our invoice to you, we send a copy of our invoice to the independent
custodian at the same time we end the invoice to you; and
(d) If we send a copy of our invoice to you, our invoice includes a disclosure that urges you to
compare the information provided in our statements with those from the qualified custodian.
You may pay custodial fees, 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
fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and
other fees and taxes on brokerage accounts and securities transactions. These fees are not included
within the wrap-fee you are charged by our firm.
Our investment advisory representatives receive a portion of the advisory fee that you pay us, either
directly as a percentage of your overall fee or as their salary from our firm. In cases where our
investment advisory representatives are paid a percentage of your overall advisory fee, this may
create an incentive to recommend that you participate in a wrap fee program rather than a non-wrap
fee program (where you would pay for trade execution costs) or brokerage account where
commissions are charged. This is because, in some cases, we may stand to earn more compensation
from advisory fees paid to us through a wrap fee program arrangement if your account is not actively
traded.
Either party may terminate the advisory agreement for Wrap Comprehensive Portfolio Management
or Wrap Asset Management services in writing at any time. Upon notice of termination, our firm will
proceed to close out your account and process a pro-rata refund of the unearned portion of the
advisory fees charged in advance. Pro-rata advisory fees for services rendered to the point of
termination will be charged if billed in arrears. If advisory fees cannot be deducted, our firm will send
an invoice for due advisory fees to the client.