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written summary of our observations and recommendations. Plans or consultations are
typically completed within six (6) months of the client signing a contract with us, assuming
that all the information and documents we request from the client are provided to us
promptly. Implementation of the recommendations will be at the discretion of the client.
(iii) Pension Consulting:
We provide pension consulting services to employer plan sponsors on an on-going or one-
time basis. Generally, such pension consulting services consist of assisting employer plan
sponsors in establishing, monitoring and reviewing their company's participant-directed
retirement plan. As the needs of the plan sponsor dictate, areas of advising could include
investment options, plan structure, and participant education.
All pension consulting services shall be in compliance with the applicable state law(s)
regulating pension consulting services. This applies to client accounts that are pension or
other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security
Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept
appointments to provide our services to such accounts, we acknowledge that we are a
fiduciary within the meaning of Section 3(21) of ERISA (but only with respect to the provision
of services described in section 1 of the Pension Consulting Agreement).
(iv) Portfolio Monitoring:
Our Portfolio Monitoring Service provides for safekeeping/housekeeping of assets on behalf
of clients with no on-going supervision, trading, or discretion with respect to securities
transactions. Clients are responsible for placing and executing their own trades, either on
their own or with another investment adviser. Clients may also contact CORE Financial for
assistance placing and executing trades. We provide non-continuous and periodic outside
account monitoring.
(v) Institutional Intelligent Portfolios:
We provide portfolio management services through Institutional Intelligent Portfolios™, an
automated, online investment management platform for use by independent investment
advisors and sponsored by Schwab Wealth Investment Advisory, Inc. (the "Program" and
"SWIA," respectively). Through the Program, we offer clients a range of investment strategies
we have constructed and manage, each consisting of a portfolio of exchange traded funds ("
ETFs") and a cash allocation. The client may instruct us to exclude up to three ETFs from their
portfolio. The client's portfolio is held in a brokerage account opened by the client at SWIA's
affiliate, Charles Schwab & Co., Inc. ("CS & Co"). We are independent of and not owned by,
affiliated with, or sponsored or supervised by SWIA, CS & Co, or their affiliates (together,
"Schwab"). The Program is described in the Schwab Wealth Investment Advisory, Inc.
Institutional Intelligent Portfolios™ Disclosure Brochure (the "Program Disclosure
Brochure"), which is delivered to clients by SWIA during the online enrollment process.
We, and not Schwab, are the client's investment advisor and primary point of contact with
respect to the Program. We are solely responsible, and Schwab is not responsible, for
determining the appropriateness of the Program for the client, choosing a suitable
investment strategy and portfolio for the client's investment needs and goals, and managing
that portfolio on an ongoing basis. SWIA's role is limited to delivering the Program Disclosure
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Brochure to clients and administering the Program so that it operates as described in the
Program Disclosure Brochure.
We have contracted with SWIA to provide us with the technology platform and related
trading and account management services for the Program. This platform enables us to make
the Program available to clients online and includes a system that automates certain key parts
of our investment process (the "System"). The System includes an online questionnaire that
helps us determine the client's investment objectives and risk tolerance and select an
appropriate investment strategy and portfolio. Clients should note that we will recommend a
portfolio via the System in response to the client's answers to the online questionnaire. The
client may then indicate an interest in a portfolio that is one level less or more conservative
or aggressive than the recommended portfolio, but
we then make the final decision and select
a portfolio based on all the information we have about the client. The System also includes an
automated investment engine through which we manage the client's portfolio on an ongoing
basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and
elects).
We do not receive a portion of a wrap fee for our services to clients through the Program.
Clients do not pay fees to SWIA in connection with the Program, [but we charge clients a fee
for our services as described below under Item 5: Fees and Compensation. Our fees are not set
or supervised by Schwab.] Clients do not pay brokerage commissions or any other fees to
Schwab as part of the Program. Schwab does receive other revenues in connection with the
Program, as described in the Program Disclosure Brochure.
B. Explanation of whether (and, if so, how) we tailor our advisory services to the individual needs
of clients, whether clients may impose restrictions on investing in certain securities or types of
securities.
(i) Individual Tailoring of Advice to Clients:
We offer individualized investment advice to clients utilizing our Comprehensive Portfolio
Management and Institutional Intelligent Portfolios services. Additionally, we offer general
investment advice to clients utilizing our Financial Consulting, Portfolio Monitoring, and
Pension Consulting services.
(ii) Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of
Securities:
Each client can place reasonable restrictions on the types of investments to be held in the
portfolio. Restrictions on investments in certain securities or types of securities may not be
possible due to the level of difficulty this would entail in managing the account. Restrictions
are limited to our Comprehensive Portfolio Management and Institutional Intelligent
Portfolios services. We do not manage assets through our other services.
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C. Participation in Wrap Fee Programs.
We do not offer wrap fee programs.
D. Disclosure of the amount of client assets we manage on a discretionary basis and the amount of
client assets we manage on a non-discretionary basis as of December 31st, 2023.
We managed $141,133,251 on a discretionary basis and $17,858,221 on a non-discretionary basis
for a total of $158,991,472.
A. Description of how we are compensated for our advisory services provided to you.
(i) Comprehensive Portfolio Management:
Our maximum fee for Comprehensive Portfolio Management services is 1.50% of assets
under management. The ultimate fee is based on the scope of the engagement and the
complexity of your circumstances. Fees to be assessed will be outlined in the signed advisory
agreement. Our firm’s fees are billed quarterly in advance based on the value of your account
on the last day of the previous quarter. Our fees are negotiable. We bill on cash unless
indicated otherwise in writing.
(ii) Financial Consulting:
We charge an hourly or flat fee for Financial Consulting services. The total estimated fee, as
well as the ultimate fee that we charge you, is based on the scope and complexity of our
engagement with you. Our hourly fee is $250. Our maximum flat fee is $2,500.
(iii) Pension Consulting:
We charge an hourly or flat fee for Pension Consulting services. The total estimated fee, as
well as the ultimate fee that we charge you, is based on the scope and complexity of our
engagement with you. Our hourly fee is $250. Our maximum flat fee is $2,500. Flat fees will
be charged annually for ongoing Pension Consulting services.
(iv) Portfolio Monitoring
Our maximum fee for Portfolio Monitoring services is 0.25% of assets under advisement. The
ultimate fee is based on the scope of the engagement and the complexity of your
circumstances. Fees to be assessed will be outlined in the signed advisory agreement. Our
firm’s fees are billed quarterly in advance based on the value of your account on the last day
of the previous quarter. Our fees are negotiable. We bill on cash unless indicated otherwise
in writing.
(v) Institutional Intelligent Portfolios:
Our maximum fee for Institutional Intelligent Portfolios is 1.00% of assets under
management. The ultimate fee is based on the scope of the engagement and the complexity
of your circumstances. Fees to be assessed will be outlined in the signed advisory agreement.