Services:
A wrap fee program is an advisory program under which a specified fee or fees, not based
directly on transactions in the client's account, is charged for advisory services, which may
include portfolio management or advice concerning the selection of other investment
advisers and the execution of the client’s transactions. However, clients with accounts in a
wrap fee program could be charged various clearing fees, exchange fees, platform fees,
postage, handling, custodial fees and other charges on transactions involving the account.
This Wrap Fee Program Brochure is limited to describing the services, fees, and other
necessary information the clients should consider prior to becoming a client within the
Wrap Fee Program sponsored by Packerland Brokerage Services, Inc. (“Packerland” or
the “Firm”). For a complete description of the other services and fees offered by
Packerland, clients should refer to its Form ADV Part 2: Firm Brochure (the “Firm
Brochure”), which is herein incorporated by reference. You may obtain a copy of the Firm
Brochure by contacting Aaron A. Doelger, Chief Compliance Officer of Packerland, at
(920) 662-9500 or via email at
[email protected]. Alternatively, you may download a
copy of the Firm Brochure by accessing the Disclosures section in the footer of the
company website at https://www.packerlandbrokerage.com
Please note that the Packerland Wrap Fee Program is distinct and different from
Packerland’s Solicitor’s Program, wherein the Firm and its investment adviser
representatives assist their clients in the selection of a third-party money manager as the
registered investment adviser and investment manager for the clients’ portfolios. If you
would like to know more about the Solicitor’s Program, please review the Firm Brochure.
You should also note that Packerland offers other advisory programs on a wrap fee basis
that are sponsored by other registered investment advisers. For example, Packerland
offers wrap fee programs sponsored by its custodian, Hilltop Securities, Inc. (“Hilltop”), a
registered investment adviser. In these programs, Packerland will act as co-fiduciary,
along with Hilltop, for all accounts using any of these advisory programs. These advisory
programs also utilize the platform sponsored by Envestnet, Inc., another registered
investment adviser (these advisory programs are hereinafter referred to as “Advisory
Programs Using Envestnet through the Hilltop Platform”). These programs are generally
described in the Firm Brochure, but are more specifically described in Hilltop’s Form ADV,
Part 2 and Hilltop’s Appendix 1 to Form ADV (the “Hilltop Disclosure Documents”). Hilltop
distributes the Hilltop Disclosure Documents to all participants that desire to enter into the
Program. Clients should consult the Hilltop Disclosure Document if they are participants in
the Hilltop Programs.
Packerland Wrap Fee Brochure 5
Asset Advisory Account (AAA)
Packerland sponsors the Asset Advisory Account (the "AAA”), a wrap fee program of
which Hilltop is the custodian. As discussed in Packerland’s Firm Brochure, Packerland
made the decision to terminate the AAA Program as of June 30, 2023 and has not
accepted any new AAA accounts since January 1, 2023. While Packerland will no longer
be accepting new accounts in 2024, clients currently in the AAA program had been notified
and advised to determine whether it would be in their best interest to allocate the funds
currently in the AAA Program to (i) a similar program using Envestnet through the Hilltop
platform (as described below) or (ii) another Packerland program. Since this AAA program
will be fully terminated on June 30, 2024, Clients currently in the AAA program should
discuss this with their IARs (including the termination date) and allocate all assets
currently in the AAA program to another Packerland advisory program or brokerage
program before the AAA program is closed and no longer available. If Clients in the AAA
program have not provided their IARs with a direction to move their assets to another
Packerland advisory program, the assets in the AAA Program will be converted to a
Packerland brokerage account as of July 1, 2024 and Packerland will no longer be acting
as a fiduciary for the brokerage account.
Clients in the AAA Program, which is terminating on June 30, 20234, are aware that
Packerland and its investment adviser representatives (“representative”) provide
investment advice, portfolio monitoring and performance reporting services for an annual
fee, which is based on the value of the assets held in an account established under the
AAA Program. After receiving advice or recommendations from Packerland and its
representatives, clients who participate in the AAA Program will utilize the AAA Program to
make his or her own determination regarding the investments that are best suited to meet
the client’s goals and objectives. All investment decisions are the sole responsibility of the
client. The AAA Program is generally not discretionary in nature (unless otherwise
indicated) and the Packerland representative will not make independent investment
decisions without first consulting with the client and obtaining client approval to execute
the investment advice being provided.
Packerland and/or Hilltop will also provide various administrative services which include
determining, at least quarterly, the fair market value of assets held in the client’s AAA
Program account(s) and producing a quarterly portfolio performance report for the client.
The quarterly performance report will detail account assets and summarize receipts and
disbursements of funds, interest and dividends received and account gain or loss for the
total account.
It is important to note that Packerland will not take possession of, or maintain custody of,
the client's funds or securities, but shall simply monitor the holdings within the portfolio and
make trades within the portfolio pursuant to the authorization granted by the client.
Possession and custody of said funds and/or securities shall be maintained by Hilltop.
Packerland Wrap Fee Brochure 6
ERISA Accounts
If the wrap fee account is established with respect to an individual retirement account or a
retirement plan subject to the provisions of the Internal Revenue Code of 1986, as
amended (the “IRC”), or the Employee Retirement Income Security Act of 1974 (“ERISA”),
as amended, certain investments may be prohibited. For example, cross agency trades,
principal trades or trades in which Packerland is acting as “agent for another” when
dealing with the client’s account are generally not permitted. No such transactions shall be
permitted unless the client is separately notified of such transaction and gives consent
prior to the completion of such transaction. In addition, Packerland shall comply with
ERISA prohibited transactions or obtain any required ERISA prohibited transaction
exemptions.
Other Wrap Fee Programs
Packerland’s Firm Brochure describes other wrap fee programs utilized by the Firm, which
are sponsored by other parties. The Firm Brochure provides a general description of
these wrap fee programs sponsored by other parties. If you would like further information
about these wrap fee programs that are not sponsored by Packerland, please advise your
representative and he or she will advise you about these programs and provide you with
their wrap fee program brochures.
Fees:
Packerland’s fees for participation in its wrap fee programs are generally described in Item
5 of the Firm Brochure under Investment Management Services for the various advisory
programs offered by Packerland, including wrap fee programs it sponsors.
Asset Advisory Account
Participants in the AAA Program agree, via the Investment Advisory Services Agreement
(the “Agreement”) to pay Packerland an annual fee, assessed quarterly, for transaction
execution, portfolio management and clearing services (the “Investment Management
Services”). Packerland’s annual fee for Investment Management Services (the “Fee”)
provided under this Agreement shall be a percentage of the net value of the assets under
management in the AAA account (the “Account”) in accordance with the negotiated fee
between Packerland and the client. Notwithstanding the negotiable nature of the fee, the
maximum annual fee for the AAA Program shall not exceed two and one-half percent
(2.5%). No portion of Packerland’s compensation shall be based on capital gains or
capital appreciation of the assets except as provided for under the Investment Advisers
Act of 1940, as amended (the “Advisers Act”).
As set forth in the Agreement, all AAA advisory fees are paid in advance. Thus, certain
additions or withdrawals exceeding the threshold established by the custodian will cause
the custodian to prorate the fees charged to the clients. Thus, the fees charged to the
Packerland Wrap Fee Brochure 7
clients will NOT be adjusted if there are additions or withdrawals that do NOT exceed the
threshold. As of the date of this brochure, the threshold established by the custodian is
$10,000.00 for both additions and withdrawals. Clients are advised to discuss how
additions or withdrawals may affect the calculation of the assets under management with
their Packerland representative.
In addition to Packerland’s Fee, the client shall also incur, relative to certain securities
purchases, charges imposed directly at the securities level (e.g. mutual fund advisory fees
and other fund expenses).
The client may also incur charges for other account services provided by Packerland or
Hilltop. Please consult with your representative regarding specific charges that you would
incur as a result of opening an Account with Packerland.
How are Fees Charged?
Accounts Initially Opened as a Brokerage Account
It is important to note that the client accounts in a wrap fee program and its associated
fees will not be in effect until after the account is approved as an advisory account, even if
the originally intent was to open an advisory account. Packerland will open all client
accounts initially as a brokerage account and fees associated with the establishment of
that account will be consistent with the fees associated with a brokerage account until the
account has been approved as an advisory account. Thus, until the account has been
approved as an advisory account, with the Agreement signed by both Packerland and its
custodian, normal brokerage fees, including transaction costs and commissions will be
assessed to the account. This would include any sales of securities to meet eligible
securities standards that may be imposed by certain portfolio managers to meet the
guidelines set by the portfolios.
Asset Advisory Account
The annual fee for Investment Management Services shall be paid on a calendar quarterly
basis, in advance, based upon the value of the client’s account in the AAA Program (the
“Account”), net of any AAA fee exempt investments, as determined by Hilltop. No increase
in the annual fee shall be effective without prior written communication with the client.
The fees are debited, by Hilltop, from the client’s AAA Account in accordance with the
terms stated in the advisory agreement, and Hilltop will remit such fee to Packerland in
accordance with required regulatory procedures.
Clients deciding to pay Packerland directly for its services should advise their
representatives of this fact and arrange for direct billing. Clients paying Packerland’s fee
directly shall note that the Packerland fee is due and payable upon receipt of Packerland’s
billing invoice.
Packerland Wrap Fee Brochure 8
What services are covered by the Program fees?
Packerland and its representatives will provide the client, upon acceptance of the client’s
wrap fee account, Investment Management Services, including portfolio reviews and
recommendations. Packerland and/or the custodian will also provide various
administrative services which include determining the fair market value of assets held in
the client’s account at least quarterly and producing a quarterly report for the client,
detailing account assets and summarizing receipts and disbursements in the Account,
interest and dividends received and account gain or loss for the Account. Packerland will
not take possession of, or maintain custody of, the client's funds or securities but shall
simply monitor the holdings and make trades within the portfolio pursuant to the
authorization granted by the client. Possession and custody of said funds and/or securities
shall be maintained by the custodian.
What services are not covered by the Program fees?
Asset Advisory Account
The AAA fees do not cover brokerage fees to the extent that (i) trades were made prior to
the Account being accepted by both Packerland and its custodian and (ii) trades are
conducted through brokers or dealers other than Packerland or Hilltop (see discussion
regarding Stepped-Out Trades in Item 5 of the Firm Brochure), and (iii) custody charges if
the client uses an entity other than Hilltop as the custodian.
Clients should also note that, under its current fee schedule which is effect as of the date
of this brochure, Packerland may charge additional clearing fees, exchange fees, postage,
handling and other charges on transactions involving the Account in accordance with the
schedule then in place at the time if the client goes over a 150% account turnover rate.
Clients should consult their representative as to the current fee as the fee schedule may
be subject to change at the sole discretion of Packerland.
The AAA fees do not include expenses of mutual funds and ETFs such as fund
management fees, which are charged to each fund directly, with an impact on the net
asset value to each of the fund's investors. Mutual funds contain internal expenses which
are separate and apart from, and in addition to, AAA fees and are generally described in
the respective funds’ prospectuses. Generally, Packerland, in selecting the funds to
purchase on behalf of the client, will select the best share class available for the clients,
which generally would not pay any distribution fee, such as those assessed pursuant to
SEC Rule 12b-1 of the Investment Company Act of 1940, as amended (“12b-1 fees”). In
the AAA program, Hilltop, as custodian for Packerland, has an automated program which
would refund these 12b-1 fees back to the client.
Packerland Wrap Fee Brochure 9
Clients should take note of the information contained in Item 5 of the Firm Brochure under
Investment Management Services.
Other Fees and Expenses
Clients may incur charges for other account services provided not directly related to the
execution and clearing of transactions, including, but not limited to, Individual Retirement
Account (“IRA”) custodial fees, safekeeping fees, wire transfer fees, interest charges on
margin loans, exchange fees, fees for transfers of securities, SEC fees and any and all
fees other than commissions or advisory fees for the purchase and sale of securities, the
fees of the custodian and reporting services.
Advisory Fees in General
Clients should note that similar advisory services may (or may not) be available from other
registered (or unregistered) investment advisers for similar or lower fees. Clients should
also note the information contained in Item 5 of the Firm Brochure under General
Information.
Limited Prepayment of Fees
As a registered investment adviser, Packerland does not require or solicit payment of fees
in excess of $1,200.00 more than six months in advance of services rendered.
Additional Information about Program fees
Once the participant’s account has been approved as an account under the wrap fee
programs, the participant receives investment advisory services, the execution of
securities brokerage transactions through the custodial broker, and custody and reporting
services for a single specified program fee. Clients are cautioned that, depending on the
level of fees charged by the executing broker-dealer and the amount of portfolio activity in
the clients' accounts, the value of the services provided under each program may exceed
the total cost of such services had they been provided separately. In addition, the fees
may be higher or lower than that charged by other sponsors of comparable wrap fee
programs.
General Information:
Termination of the Advisory Relationship
Packerland and/or the client may terminate the Agreement for the wrap fee programs at
any time and for any reason, by providing written notice of such election to the other party.
This agreement will also terminate automatically upon receipt by Packerland or Hilltop of
legal notice of the death of the client. Termination of this agreement will not affect the
client’s liability or responsibility with regard to transactions for the client’s account(s) in the
Packerland Wrap Fee Brochure
10
wrap fee programs and the client agrees to be responsible for any commissions, fees or
expenses prior to or after such termination.
Transaction processing charges paid to Packerland are not subject to refund in the event
of termination of the agreement because they will be incurred at the time a service is
performed. Upon request, prior to transfer of assets, all fees due under the agreement at
termination will be deducted from the client’s account(s) in the wrap fee programs before
assets are delivered from the account. The client may also terminate the agreement within
five (5) business days of the effective date. If the client elects to terminate the agreement
within the five (5) business days of the effective date, Packerland will make an adjustment
to its fee process such that the client would not be paying a fee for Packerland’s services.
Upon termination of any account, any prepaid, unearned fees will be promptly refunded
within 30 days. In calculating a client’s reimbursement of fees, we will pro rate the
reimbursement according to the number of days remaining in the billing period.
Grandfathering of Minimum Account Requirements
Advisory clients are subject to Packerland’s minimum account requirements and advisory
fees in effect at the time the client entered into the advisory relationship. Therefore,
Packerland’s minimum account requirements may differ among clients.
ERISA Accounts
Packerland offers non-discretionary investment advisory services and administrative
services (each a form of “Retirement Plan Services”) that are designed to assist plan
sponsors of employee benefit plans (“Sponsor(s)”). When providing any non-discretionary
investment advisory service, Packerland will solely be making investment
recommendations to the Sponsor and the Sponsor retains full discretionary authority or
control over assets of the Plan. Packerland agrees to perform any non-discretionary
investment advisory service to the Plan, as a fiduciary, as defined in ERISA Section
3(21)(A)(ii) and will act in good faith and with the degree of diligence, care and skill that a
prudent person rendering similar services would exercise under similar circumstances.
When providing any administrative service, Packerland may support the Sponsor with Plan
governance and committee education, vendor management and service provider selection
and review, investment education or provide Plan participant non-fiduciary education
services. Packerland agrees to perform any administrative service solely in a capacity that
would not be considered a fiduciary under ERISA or any other applicable law.
Custody
Clients should note that by signing the Agreement, they have directed the custodian to pay
the advisory fee on a scheduled basis without any additional prior notice. All account
assets, transactions, and advisory fees will be shown on the monthly or quarterly
Packerland Wrap Fee Brochure 11
statements provided by the custodian. As part of this billing process, the client's custodian
is advised of the applicable fee schedule so the custodian can calculate the amount to be
deducted from that client's account for the investment advisory fee. On at least a quarterly
basis, the custodian is required to send to the client a statement showing all transactions
within the account during the reporting period.
Because the custodian calculates the amount of the fee to be deducted, it is important for
clients to carefully review their custodial statements to verify the accuracy of the
calculation, among other things. Clients should contact Packerland directly if they believe
that there may be an error in their statement.
When performing retirement plan services, custody of all retirement plan assets will be
maintained with a third-party custodian selected by the Sponsor, and the retirement plan
recordkeeping will be provided by a third-party recordkeeper selected by the Sponsor. We
will not serve as a custodian of a retirement plan for which we provide advisory or
investment management services.
Packerland does not have actual or constructive custody of client accounts. To the extent
that Packerland acts as Trustee for certain accounts, Packerland may have “inadvertent
custody” of certain accounts. In those cases, an independent audit will be done.
Investment Discretion
Clients may hire Packerland to provide discretionary asset management services, in which
case it place trades on a client's behalf without contacting the client prior to each trade to
obtain the client's permission. Packerland’s discretionary authority includes the ability to do
the following without contacting the client:
determine the security to buy or sell; and/or
determine the amount of the security to buy or sell.
Clients give Packerland discretionary authority when they sign an investment advisory
agreement and select the discretionary option. Clients may limit this authority by giving
Packerland and its investment adviser representatives with written instructions. Clients
may also change or amend such limitations by once again providing Packerland and its
investment adviser representatives with written instructions.
Brokerage Practices
Packerland does not have any soft-dollar arrangements and does not receive any soft-
dollar benefits.
In addition to being a registered investment adviser, Packerland is also registered as a
broker-dealer and is a member of the Financial Industry Regulatory Authority (“FINRA”).
Packerland Wrap Fee Brochure 12
As a matter of policy and practice, Packerland does not generally execute client trades on
a block trade basis and, therefore, implements client transactions separately for each
account. Consequently, certain client trades may be executed before others, at a different
price and/or commission rate. Additionally, our clients may not receive volume discounts
available to advisors who utilizes block trades for clients.
Compensation:
Packerland, in addition to being a registered investment adviser, is registered as a broker-
dealer and is a member of FINRA. Since the investment adviser representative is also a
registered representative of Packerland’s broker-dealer, the investment adviser
representative will receive compensation in the form of a portion of all advisory fees paid
to Packerland pursuant to the Agreement. Further, the investment adviser representative
may also be a registered securities representative affiliated with Packerland. In that
capacity, the registered representative may provide securities brokerage services through
Packerland which involve securities not transacted in the client’s AAA account pursuant to
the terms and conditions of this agreement. Such securities transactions may result in a
commission to be paid to Packerland and, if so, the affiliated registered representative will
receive a portion of said commission.
Unless specifically excluded by the terms of the Agreement, account balances in the
money market funds are included as part of the account. Consequently, any asset-based
fees owed under the Agreement will be based, in part, on the balances in these
investments. In addition, the custodian may serve as adviser, distributor, or administrator
to the money market funds and receive compensation for those services. The money
market funds may also pay shareholder servicing, shareholder communication, sub-
accounting, and 12b-1 fees and charges to the custodian, as well as fees for the execution
of purchases of fund shares, or for trade clearance, settlement, custodial or other functions
ancillary thereto. These fees and charges are expenses of the money market funds, which
the client will bear, indirectly, as a fund shareholder. Some money market funds make a
“Distribution Payment” to the clearing firm utilizing their funds as the investment vehicle for
overnight cash sweep accounts. Some clearing firms will pay a portion of the Distribution
Payments they receive to their participants. Packerland has advised its clearing firm that it
does not want to be a recipient of any Distribution Payments and such Distribution
Payments should be rebated back to the client. Similarly, Packerland has caused its
clearing firm to establish an automated program which will capture any 12b-1 fees which
would normally be payable to Packerland and rebate those 12b-1 fees back to its clients.
Packerland and the custodian are permitted to route, within the AAA Program, client
orders for over-the-counter and listed equity securities to selected market makers or
market centers for execution. While they have an obligation to provide best execution
services to the client, the client should note that both entities may receive compensation in
the form of a per-share cash payment for directing order flow to these market makers or
market centers.
Packerland Wrap Fee Brochure 13
Some transactions executed for an AAA account may be effected in the secondary or third
market. In this event, Packerland and/or Hilltop may receive other remuneration or
compensation and will furnish the source and amount upon written request.
Depending on the fee percentage charged, the trading activity and types of securities
utilized in the client’s wrap fee account, the total costs to the client will be more or less
than the client would incur if the client paid separately for investment advice, brokerage
and other services provided by each program. Packerland may, therefore, have a financial
incentive to recommend these programs over other services offered by Packerland.
Various vendors, product providers, distributors and others may provide non-monetary
compensation by providing training, education and publications that may further
Packerland’s employees’ skills and knowledge. Some vendors may occasionally provide
Packerland with gifts, meals and entertainment of reasonable value consistent with
industry rules and regulations. Packerland may, in accordance with its compliance policies
and its code of ethics, accept reasonable lodging and/or travel expenses from third parties
related to educational seminars (including those regarding products it recommends);
reimbursement of its reasonable lodging, travel expenses and costs related to its due
diligence investigations; and/or third-party payment of its conference fee costs or fees to
attain professional designations. The existence of these gifts, meals and entertainment
provided by these vendors and others, which are consistent with industry rules and
regulations and Packerland’s Code of Ethics, may create a conflict of interest that could
influence Packerland and its representative to use these vendors that may have higher
costs or less favorable services than other suitable alternatives which do not provide
equivalent compensation to Packerland or its representatives.
Mutual Funds
All fees paid to Packerland for investment advisory services are separate and distinct from
the fees and expenses charged by mutual funds and/or ETFs to their shareholders
(collectively referred to hereinafter as “mutual fund fees”). Clients should note that many
mutual funds have different share classes, with some share classes paying a distribution
fee to broker-dealers (a “12b-1 fee”) and others that do not. Consequently, share classes
that do not pay a 12b-1 fee are less expensive for clients.
The mutual fund fees and expenses, including those assessed by different mutual fund
share classes, are described in each fund's prospectus. These fees will generally include a
management fee, other fund expenses, and a possible distribution fee. If the fund also
imposes sales charges, a client may pay an initial or deferred sales charge. Packerland
will generally not recommend a share class that pays a 12b-1 fee to Packerland or its
broker-dealer when there is another share class with similar characteristics that does not
pay a 12b-1 fee to the broker-dealer. However, in situations where the only share class
that is available is a share class that pays a 12b-1 fee, Packerland and its representatives
will disclose the fee to the clients and recommend that share class if that share class is in
Packerland Wrap Fee Brochure 14
the best interest of the client.
A client could invest in a mutual fund directly, without Packerland’s services or the
services of the third-party money manager. In that case, the client would not receive the
services provided by Packerland which are designed, among other things, to assist the
client in determining which mutual fund or funds are most appropriate to each client's
financial condition and objectives. The client should review both the fees charged by the
funds and Packerland’s fees to fully understand the total amount of fees to be paid by the
client and to thereby evaluate the advisory services being provided.
All or a portion of the wrap fee accounts may be held in cash or cash equivalents issued
by money market mutual funds. Packerland’s custodian may receive fees (a “Distribution
Payment”) for the services provided as set forth in the prospectuses of these mutual funds.
Packerland has advised its custodian that it does not want to participate in any Distribution
Payments and, to the extent a Distribution Payment is made, Packerland has directed its
custodian to rebate such Distribution Payment back to the client.
As part of the wrap fee programs, the client should receive of a copy of mutual fund
prospectuses and the client should refer to each mutual fund prospectus for detailed
information about any and all fees.
General Fee Practices
Asset Advisory Account
Transactions that have not settled prior to the last trading day of a calendar quarter may
be included in either the current or the following calendar quarter, as determined by
Packerland pursuant to its policies, procedures and practices. Fees are not charged on the
basis of a share of capital gains or capital appreciation of assets in the advisory client’s
account (sometimes referred to as “performance-based fees”). Unless otherwise provided
in the investment advisory agreement, Packerland will calculate fees on the basis of a
365-day year so that the amount payable each quarter will be based on the actual number
of calendar days in that quarter. If a client terminates their account prior to the end of any
quarter, they will receive a pro-rated refund, if any, of advisory fees paid in advance.
Unless otherwise limited by the custodian and subject to usual and customary securities
settlement procedures, a client may make additions or withdrawals from their account at
any time. Clients should understand that additions to or withdrawals from certain accounts
may affect the fees for the accounts as the fees are calculated based upon the assets
under management. For example, certain additions or withdrawals exceeding the
threshold established by the custodian will cause the custodian to prorate the fees that are
charged to the client. As of the date of this booklet, the established threshold is
$10,000.00 for both additions and withdrawals. Clients are advised to discuss how
additions or withdrawals may affect the calculation of the assets under management with
their Packerland representative. Additions and withdraws from certain accounts may also
Packerland Wrap Fee Brochure 15
create a tax liability which should be discussed with a qualified tax professional. No fee
adjustment will be made for appreciation or depreciation in the value of any account during
the fee calculation period. No refund or other adjustment of a fee already paid will be
made as a result of a decline in value of the account (whether due to market losses or
withdrawals). Adjustments to the fees are made by the custodian in the event that deposits
or withdrawals exceed the established threshold set forth above for those accounts where
the fees are collected in advance. In the event the investment advisory agreement is
terminated within five days after its initial execution, all advisory fees will be refunded
pursuant to the terms in the investment advisory agreement.
In order to seek best execution and minimize market impact, trades can be “stepped-out”
in order to gain best execution and minimize market impact. In some instances, stepped-
out trades are executed by the other firms without any additional commission or markup or
markdown, but in other instances, the executing firm imposes a commission or a markup
on the trade. If a client’s investment sub manager steps-out trade orders for the client’s
account with a broker-dealer other than Packerland’s executing broker, and the other
broker-dealer imposes a commission or equivalent fee on the trade (including a
commission embedded in the price of the investment), the client will incur trading costs in
addition to the Advisory Fee. See Item 12, Brokerage Services, below.
The client should note that by signing an investment advisory agreement, they have
directed the custodian to pay the advisory fee as instructed by Packerland or any other
third-party money manager on a scheduled basis without any additional prior notice. All
account assets, transactions, and advisory fees will be shown on the monthly or quarterly
statements provided by the custodian.