We pay an asset-based fee to our custodian, Charles Schwab & Co., Inc. (“Schwab”), based on
the total value of client assets custodied on their platform. It is common in the industry for wrap
fee advisers to pay a transaction-based fee to their custodian for executing transactions in client
accounts. However, wrap fee advisers that pay transaction-based compensation have a financial
incentive to trade as little as possible to minimize expenses. Wrap fee advisers that pay asset-
based compensation, like our firm, have the opposite financial incentive. Nevertheless, our firm
seeks to adhere to our fiduciary duty to act in our clients’ best interest by placing their interests
above our own and by trading when appropriate for our clients’ financial circumstances and
objectives. We do not charge our clients higher advisory fees based on their trading activity. 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 trade execution costs are passed directly to you by the executing
broker.
Our Wrap Advisory Services
Our Wrap 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 or video
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 (“ETFs”), mutual funds, individual stocks or bonds, fee-based annuities, 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
annually. 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.
Fee Schedule
Assets Under Management Annual Percentage of Assets Charge:
$0 to $249,999.99 2.95%
$250,000 to $499,999.99 2.50%
Over $500,000 2.00%
Our firm’s fees are billed on a pro-rata annualized basis, quarterly in advance based on the value
of your account on the last day of the previous quarter, which is typically the end of January, April,
July and October. Adjustments will be made for deposits and withdrawals of cash and securities
during the billing period for amounts of $1,000 or greater. For example, if a client withdraws cash
or securities from their account exceeding $1,000 mid-billing period, they would receive a prorated
fee refund based on the amount of the withdrawal and the remaining days in the billing period.
The fee refund would be applied at the next quarterly billing and would reduce that billing period’s
fee. If a client deposits cash or securities into their account exceeding $1,000 mid-billing period,
a prorated fee would be assessed based on the amount of the deposit and the remaining days in
the billing period. The prorated fee would be applied at the next quarterly billing
and would
increase that billing period’s fee.
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Fees generally are negotiable at the discretion of our firm and will be automatically deducted from
your managed account. As part of the fee deduction process, you understand and acknowledge
the following:
a) Your independent custodian sends statements at least quarterly to you showing the market
values for each security included in the Assets and all disbursements in 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; and
c) If we send a copy of our invoice to you, it will include a legend urging you to compare
information provided in our statement with those from the qualified custodian.
Please note the first advisory fee charged to new client accounts includes the fee charged on the
regular billing date in advance for the first full quarter as well as a one-time pro-rata advisory fee
in arrears for services rendered between the date of receipt of assets and the end of the previous
quarter.
We do not permit check writing or debt card use within investments accounts under our
management where we trade securities (stocks, bonds, etc.). Any withdrawals from an
investment account would need to be requested directly from our office or set up via automatic
payment.
If agreed upon in the signed advisory agreement, our firm will manage client account(s) that are
held at a custodian that is not directly accessible by our firm using the Pontera Order Management
System (“Pontera”). Pontera enables our firm to view and manage held away accounts. Our firm
will charge an advisory fee of up to 1.50% for managed held away accounts. If a client’s advisory
fee is below 1.50%, we will charge an advisory fee in accordance with their current advisory fee
rate. The advisory fee payable for any held away accounts will be deducted directly from another
client account. If there are insufficient funds available in another client account or our firm believes
that deducting the advisory fee from another client account would be prohibited by applicable law,
our firm will invoice the client directly.
Other Types of Fees & Expenses:
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, 12b-
1 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. Please note, we do
not recommend or offer the wrap program services of other providers. You will also be charged
fees for trades executed away from our recommended custodian.
Our recommended custodian, Schwab, does not charge transaction fees for U.S. listed equities,
exchange traded funds, and options (subject to $0.65 per contract fee). This means that, in most
cases, when we buy and sell these types of securities, we will not have to pay any commissions
to Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering
into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a
wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and
advisory services separately. To see what you would pay for transactions in a non-wrap account
please refer to Schwab’s most recent pricing schedules available at schwab.com/aspricingguide.
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