Services
Private Portfolio Partners LLC (“PPP” or the “Firm”) offers six (6) primary types of
wrap fee programs (“Programs”), which are investment programs wherein the
investor pays one stated fee that includes portfolio management, asset allocation,
transaction and execution, and preparation of quarterly performance reports. The fees
paid to the wrap fee Program will be given to PPP as a management fee.
For all of the assets in its primary Programs, PPP provides continuous and regular
supervisory or management services (as defined by the SEC) based on the Client’s
individual goals, objectives, risk tolerance, time horizon, liquidity needs, investment
assets and income (“financial circumstances”) utilizing the investment strategy
selected by the Client. IARs obtain a financial profile for each Client to aid in the
construction of a portfolio that matches the Client’s specific situation. Many Clients
maintain “household” accounts, in which multiple accounts for an individual or
members of a family may be managed jointly to maximize efficiencies. (The term
“Client” includes such households, for purpose of this wrap brochure.) For all of the
different types of Programs, the IAR will assist Clients in assessing their goals, risk
tolerance, income and tax situation and select an investment strategy and asset
allocation that are appropriate for the Client’s specific circumstances. However, PPP
does not provide tax advice to Clients.
PPP, through its IARs, is available to Clients on an ongoing basis to discuss Client
financial circumstances, the selected portfolio and the securities therin or to process
instructions from Clients concerning advisory assets.
The investment strategies used by PPP vary from Client-to-Client, as warranted by
the individual circumstances.
Clients are advised to promptly notify PPP if there are changes in their financial
situation, investment objectives or if they wish to impose any reasonable restrictions
upon the Firm’s investment management services. Clients can engage the Firm to
manage all or a portion of their assets on a discretionary or non-discretionary basis
by entering into one or more written agreements with the Firm. Clients are typically
required to enter into additional written agreements with the Custodian for the
account or other parties that are not affiliated with PPP.
All investments have risk and there is no guarantee that utilizing the asset
management services of PPP or its IARs will produce favorable results.
At the present time PPP offers to Clients the Wrap Programs described below.
1. Strategic Wealth Management II Program (“SWM II”)
SWM II is a Program where PPP, through its IARs, provides ongoing investment
management of Client assets custodied at LPL. The IAR reviews the Client’s
financial circumstances and exercises discretion to determine the securities to be
bought or sold in the Client’s account, the amount of securities to be bought or
sold and the timing of the purchases and sales of the securities. The types of
securities used in this Program typically include mutual funds, unit investment
trusts, closed–end funds, exchange-traded products, equities, options, and fixed
income securities.
IARs provide investment management services tailored to the individual needs
of the Client based on the investment objectives chosen by the Client. Clients
may impose restrictions on investing in certain securities or groups of securities
by indicating in the Account Application. Given the long-term nature of many
SWM II strategies, an account may have little or no turnover during a given
period.
There is no minimum required account value in the SWM II Program. Other
than direct investments, assets in the Program are custodied at LPL Financial,
which is unaffiliated with PPP. Clients should refer to their account application
package for specific information on LPL’s custody and administrative fees. If
direct investments are utilized, the assets will be identified on the LPL Financial
account statements, but the actual securities are often held with and valued by the
issuer of the security.
2. Manager Asset Select Program (“MAS”)
MAS is an LPL Financial Sponsored Advisory Program that provides Clients
access to the investment advisory services of professional portfolio management
firms fo the individual management of Client accounts. The Program offers two
alternatives (i) the Separately Managed Account Platform (“SMA Platform”);
and (ii) the Model Portfolio Platform (“MP Platform”) (collectively “Platforms”).
For both Platforms, the IAR will assist Client in identifying a third-party portfolio
manager (“Portfolio Manager”) from a list of Portfolio Managers made available
by LPL. The Portfolio Manager manages Client’s assets on a discretionary basis.
The IAR will provide initial and ongoing assistance regarding the Portfolio
Manager selection process and serves as the point of contact between the Client
and Portfolio Manager with regards to changes in the Client’s investment
objective, financial circumstances and investment restrictions (if any).
SMA Platform
The SMA Portfolio Manager selected by the Client has ongoing
investment discretion regarding the investment and reinvestment of
account assets in accordance with the investment objective restrictions
and guidelines set forth in the Investment Management Agreement and
Account Application. The SMA Portfolio Manager independently
determines whether to accept the Client account based on the content of
the Account Application, suitability and whatever other factors the SMA
Portfolio Manager has deemed appropriate. The SMA Portfolio Manager
has the sole authority to determine the securities to be purchased, sold or
exchanged and which portion, if any, of the assets shall be held
uninvested. The SMA Portfolio Manager has discretion to invest among
a broad variety of security types, including equities, fixed income
securities, options, mutual funds and ETFs. The does not play a role in
the selection of securities to be purchased or sold.
MP Platform
Under the MP Platform, LPL provides ongoing discretionary investment
advice regarding the investment and reinvestment of account assets in
accordance with the Model Portfolio selected. LPL is expected to closely
track the Model Portfolio, making modifications only to redress account
issues, including tax loss harvesting, rebalancing, and to ensure that
investment restrictions are being followed. The IAR does not play a role
in the selection of securities to be purchased or sold.
LPL selects and reviews SMA Portfolio Managers and MP Model Advisors for
the Platforms based on quantitative, qualitative and infrastructure criteria.
Portfolio Managers and Model Advisors that are “Recommended” by LPL
Research are subject to more rigorous selection and review process. Clients
should speak to their IAR regarding whether the Portfolio manager or Model
Advisor being considered for selection or that has been selected by the Client is
“Recommended” or “Participating.”
A minimum account value of $100,000 is required for the MAS Program;
however, in certain instances, the minimum account size may be lower or higher.
Clients should note that an account will not be invested until the applicable
minimum for the investment strategy or Model Portfolio has been reached.
Clients should consult with their IAR to obtain more information about the
applicable investment minimum based on the strategy or Model Portfolio
selected.
LPL acts as Custodian to MAS accounts, provides brokerage and execution
services as the broker-dealer on transactions, and performs administrative
services, such as quarterly performance reporting to Clients. PPP is unaffiliated
with LPL and the third-party managers utilized under the Program. Clients should
refer to their account application package and the third-party manager disclosure
brochure for specific information on LPL’s management fees and fees imposed
by third parties.
3. Model Wealth Portfolios Program (“MWP”)
MWP is an LPL Financial Sponsored Advisory Program that offers Clients
professionally managed mutual fund and ETF asset allocation models. The IAR
will obtain the necessary financial data from the Client, assist the Client in
determining the suitability of the MWP Program and assist the Client in setting
an appropriate investment objective. The IAR will initiate the steps necessary to
open an MWP account and have discretion to select a model portfolio designed
by LPL’s Research Department consistent with eh Client’s stated investment
objectives. LPL’s Research Department or third-party portfolio strategists are
responsible for selecting the mutual funds or ETFs within a model portfolio and
for making changes to the mutual funds or ETFs selected.
Portfolio Strategists are independent investment advisor firms. Portfolio
Strategists provide LPL on an ongoing basis with a Portfolio that includes
recommended asset allocations and funds. LPL enters into an agreement with the
Portfolio Strategist for these Portfolio services. Other than the IAR and LPL,
Portfolio Strategists do not have discretion from the Client to implement the
Portfolio and do not provide individualized investment advice to specific
program Clients. In certain cases, a Portfolio may consist only of mutual funds
and/or ETFs within the same fund family or within affiliated fund families. In
such a Portfolio, the Portfolio Strategist will select only those funds within the
fund family or affiliated fund families, and a third-party Portfolio Strategist or its
affiliates may earn two levels of fees with respect to the assets; a strategist fee
and fund-level fees, including fund management fees.
The Client will authorize LPL to act on a discretionary basis to purchase and sell
mutual funds and ETFs and to liquidate previously purchased securities. The
Client will also authorize LPL to effect rebalancing for MWP accounts.
MWP requires a minimum asset value for a Program account to be managed. The
minimums vary depending on the Portfolio(s) selected and the account’s
allocation amongst Portfolios. The lowest minimum Portfolio is $25,000. In
certain instances, a lower minimum for a Portfolio will be permitted. Note that an
account will not be invested according to a Portfolio or Portfolios until the
applicable minimum for the Portfolio(s) and allocation has been reached. Clients
should consult with IAR to obtain more information about the applicable investment
minimum based on the Portfolio(s) selected and the allocation amongst Portfolios.
LPL acts as Custodian to MWP accounts, provides brokerage and execution
services as the broker-dealer on transactions, and performs administrative
services, such as quarterly performance reporting to Clients. PPP is unaffiliated
with LPL. Clients should refer to their account application package for specific
information on LPL’s management fees and fees imposed by third parties.
4. Optimum Market Portfolios Program (“OMP”)
OMP is an LPL Financial Sponsored Advisory Program offering Clients the
ability to participate in a professionally managed asset allocation program using
Optimum Funds shares. Under OMP, the Client authorizes LPL on a
discretionary basis to purchase and sell Optimum Funds pursuant to investment
objectives chosen by the Client. The IAR will assist the Client in determining
the suitability of the OMP for the Client and assist the Client in setting an
appropriate investment objective. The IAR will have discretion to select a mutual
fund asset allocation portfolio designed by LPL consistent with the Client’s
investment objective. LPL will have discretion to purchase and sell Optimum
Funds pursuant to the portfolio selected for the Client. LPL will also have
authority to rebalance the account.
A minimum account value of $10,000 is required for the OMP Program. In
certain instances, a lower minimum for the Program will be permitted. LPL acts
as Custodian to OMP accounts, provides brokerage and execution services as the
broker-dealer on transactions, and performs administrative services, such as
quarterly performance reporting to Clients. PPP is unaffiliated with LPL. Clients
should refer to their account application package for specific information on
LPL’s management fees and fees imposed by third parties.
5. SEI Mutual Fund Models Program (“SEI”)
The SEI Program is a professionally managed mutual fund models Program in
which SEI Investments Management Corporation (SIMC) develops various
model mutual fund asset allocation portfolios designed to be invested in
accordance with the Client stated investment objective. The IAR obtains the
necessary financial data from the Client, assists the Client in determining the
suitability of the Program and assists the Client in setting an appropriate
investment objective. The IAR has discretion to select actively managed mutual
fund model portfolios comprised of SEI funds model portfolio of funds consistent
with the Client’s stated investment objective. SEI has discretion to buy and sell
mutual funds in the account and will invest the account based on the Portfolio
selected. The IAR and Client can decide whether to subject the accounts to
automatic quarterly rebalancing so the allocation selected by the Client remains
consistent over time. Given the long-term nature of most of the mutual fund
strategies, an SEI account may have little or no activity during any given period.
Clients should be aware that PPP provides LPL access to confidential Client
information including personally identifiable information (“PII”) and other
information including financial information, transactions and holdings for
accounts established through SEI even if the Client does not
establish an account
through LPL.
There is no minimum required account value for the SEI Mutual Fund Portfolio
Program. Assets in the SEI Mutual Fund Portfolios Program are custodied at SEI
Private Trust Company (“SPTC”), which is unaffiliated with PPP. Clients should
refer to their account application for specific information on SPTC custody fees
and management fees.
6. Fidelity Institutional Wealth Services Program
Fidelity IWS is a Program where PPP, through its IARs, provides ongoing
investment management of Client assets custodied at Fidelity. The IAR reviews
the Client’s financial circumstances and exercises discretion to determine the
securities to be bought or sold in the Client’s account, the amount of securities to
be bought or sold and the timing of the purchases and sales of the securities. The
securities used in this Program typically include mutual funds, closed–end funds,
exchange-traded products, equities, options, and fixed income securities.
IARs provide investment management services tailored to the individual needs
of the Client based on the investment objectives chosen by the Client. Clients
may impose restrictions on investing in certain securities or groups of securities
by indicating in the Agreement. Given the long-term nature of many individual
strategies employed in the Fidelity Program, an account may have little or no
turnover during a given period.
Clients should be aware that PPP provides LPL access to confidential Client
information including personally identifiable information (“PII”) and other
information including financial information, transactions and holdings for
accounts established through Fidelity even if the Client does not establish an
account through LPL.
There is no minimum required account value in the Fidelity IWS Program.
Fidelity is unaffiliated with PPP. Clients should refer to their account application
package for specific information on Fidelity’s custody and other applicable fees.
Fees and Compensation
When a Client engages PPP to provide investment management services, the
Client is charged a fee. IARs set their own asset-based fee for their services, so
long as their asset-based fee does not exceed the Firm’s maximum fee of 2%.
IARs consider various factors in determining what fee to charge, which may
include, among other things, the nature and size of the overall Client relationship
with the IAR. Clients may negotiate fees for the IAR’s service. Clients with
assets in MAS, MWP, OMP, and SEI will also pay fees directly to other parties,
such as third-party asset manager(s), Custodian, and platform manager. These
fees are in addition to the fee the Client pays to PPP. Regardless of Program
selected, Clients will pay internal expense and management fees in connection
with transactions in certain types of securities such as mutual funds, exchange
traded products and direct investment products which can vary considerably.
Clients should be aware that if there is little or no trading activity in the account,
the Client will pay more in advisory fees than commission charges if the account
was a non-managed account or if such services were purchased separately.
The fee charged for assets in SWM II and Fidelity IWS Programs is included in
the written Investment Management Agreements between PPP and the Client.
For MAS, MWP and OMP Programs, the fees are covered in the written
Investment Management Agreement between PPP and the Client in conjunction
with separate agreements directly between the Client and third-party money
manager and Custodian and platform manager. For these programs, Clients pay
separate fees to those managers and to PPP; although both fees may be deducted
from the assets managed by the Custodian and/or third-party manager.
For SWM II, MAS, MWP, and OMP Programs, fees are due and payable in
advance and are based upon the ending account values as of the close of business
on the last day of the previous calendar quarter. Fees are calculated and deducted
from the managed account by LPL, the qualified Custodian of record. Fees for
the initial quarter are adjusted pro rata based upon the number of calendar days
in the calendar quarter that the Investment Advisory Agreement goes into effect.
If assets are deposited into or withdrawn from an account after inception of a
billing period, the fee payable with respect to such assets is prorated to reflect the
change in portfolio value. The advisory relationship may be terminated by the
Client, PPP or by third-parties to the contract in accordance with the provision of
the Investment Management Agreement. The Client receives a pro rata refund
of any prepaid unearned advisory fees. Clients receive an account statement from
their qualified Custodian at least quarterly. The statement includes the amount of
any fees debited or credited, as the case may be, from the Client’s’ account
pursuant to written authorization.
Advisory fees for the SEI Program are calculated daily and payable monthly in
arrears net of any income, withholding or other taxes. Fees are calculated and
deducted from the managed account by the qualified Custodian of record. The
first payment is calculated based on the number of days assets are placed in the
account during the calendar month. The advisory relationship may be terminated
by the Client, PPP or by third-parties to the contract in accordance with the
provision of the Investment Management Agreement. If an account is terminated
prior to the end of a calendar month, the terminating Client will pay prorated fees
due up to the account termination date. Clients receive an account statement from
their qualified Custodian at least quarterly. The statement includes the amount of
any fees debited or credited, as the case may be, from the Client’s’ account
pursuant to written authorization.
Advisory fees for the Fidelity IWS Program are due and payable in advance and
are based upon the ending account values as of the close of business on the last
day of the previous calendar quarter. Fees are calculated by PPP and deducted
from the managed account by Fidelity, the qualified Custodian of record. Fees
for the initial quarter are adjusted pro rata based upon the number of calendar
days in the calendar quarter that the Investment Advisory Agreement goes into
effect. The advisory relationship may be terminated by the Client, PPP or by
third-parties to the contract in accordance with the provision of the Investment
Management Agreement. The Client receives a pro rata refund of any prepaid
unearned advisory fees. Clients receive an account statement from their qualified
Custodian at least quarterly. The statement includes the amount of any fees
debited or credited, as the case may be, from the Client’s’ account pursuant to
written authorization.
While IARs recommend investment advisory Programs based on what they
believe is appropriate for the Client, a conflict of interest exists for the IAR to
recommend Programs offered through LPL because a percentage of the fee
payout to the IAR is higher than Programs offered through Fidelity.
Since PPP began providing these services, it has had other asset-based fee ranges
in effect, which may have been lower or higher than that described above. As
new fee structures are put into effect, they are generally made applicable only to
new Clients, and fees to existing Clients are generally not affected.
Other Types of Fees and Expenses
Clients are responsible for the payment of all third-party fees such as Custodian
fees, charges imposed directly by a mutual fund, index fund, exchange traded
fund or direct investment which shall be disclosed in the fund’s prospectus or
issuer’s disclosure document (i.e., management fees and other expenses), mark-
ups and mark-downs, spreads paid to market makers, fees for trades executed
away from the Custodian (“step-out trades”), platform fees, wire transfer fees and
other fees and taxes on brokerage accounts and securities transactions. The
Custodian for third-party managers may impose other charges. These fees are not
included within the wrap-fee Clients are charged by PPP. As noted throughout,
Clients are encouraged to review all documentation provided by those managers
for full and current details regarding their practices. Please contact your IAR if
you have any questions.
Third-party money managers are permitted to place trades through LPL, in its
capacity as a broker-dealer, or through other broker-dealers if the third-party
manager determines that such other broker-dealer is providing best execution
considering all applicable circumstances. If a third-party manager executes
trades through a broker-dealer other than LPL, there will most likely be a
commission or mark-up on the trade that wouldn’t have been charged if the trade
was executed through LPL. Clients are encouraged to review the disclosure
brochure for the third-party manager selected for more information regarding
their practices.
Clients are advised to review the Investment Advisory Brochures and
applications/contracts/agreements with applicable third-parties for complete
information on how fees are charged by such parties because their processes for
charging fees may change from time-to-time. If you have questions about a
particular Program, Custodian, or fees please contact your IAR
Internal Product Fees and Expenses
Additionally, all collective instruments, including mutual funds, exchange traded
products, unit investment trusts, and direct investments, such as structured
products, alternative investments, and variable annuities have their own internal
fees which are also disclosed in each product’s offering documents and vary
considerably. These internal charges often include operating expenses,
management fees, administrative fees, 12b-1 fees, redemption fees, M&E&A
fees, fees for additional riders on the contract, and other fees and expenses that
increase the expense ratio of the investment. These fees are a second layer of
fees and in addition to the wrap fees charged by PPP. PPP or its IARs do not
directly or indirectly receive any compensation linked to a product’s internal fees.
If Clients transfer in B or C share classes of mutual funds, and if such shares are
liquidated after being transferred to PPP, those shares will incur a contingent
deferred sales charge (“CDSC”) from the mutual fund company if they are within
the CDSC holding period.
PPP has available for purchase through its Custodians, mutual funds which are
no-load or load-waived share classes and therefore not subject to any upfront
sales charge (Platform Shares). Clients should be aware that load-waived funds
charge 12b-1 fees, which can vary considerably. Clients should further
understand that IARs can select more expensive share classes available on the
Custodian’s Platform when a lower-cost share class is available for the same
fund. All 12b-1 fees are retained by the Custodian and not paid to PPP or its IARs
and are not credited to Clients’ advisory accounts.
Most mutual funds available in the Programs may be purchased directly from the
issuer. Therefore, Clients could generally avoid the second layer of fees by not
using the advisory services of PPP and by making their own decisions regarding
the investment. PPP encourages all Clients to closely review the investment’s
prospectus or offering documents for all such investments with their IARs and to
consider aggregate costs. Clients should contact their IAR with any questions
about particular product fees and expenses.
Clients should understand that mutual fund share classes available on a particular
Custodian’s Platform in many cases will not be the least expensive share class
that the mutual fund has available. Share classes are selected by Custodians to
be included on their platforms in certain cases because the share class pays the
Custodian compensation for the administrative and record keeping services the
Custodian provides to the mutual fund. PPP or IAR does not share directly or
indirectly in any compensation received by Custodians for these services.
While PPP endeavors to use the lowest-cost mutual fund share class available,
and periodically reviews its holdings in order to convert higher cost shares to
lower cost shares, the Firm cannot ensure that all Clients will hold the lowest cost
share class available on the Platform at any given time. Further, some third-party
money managers are more careful about utilizing the lowest cost share class than
others.
Third-Party Manager Step-out Trades
Third-party managers are permitted to place trades through the broker-dealer
associated with the Program, or through other broker-dealers if the third-party
manager determines that such other broker-dealer is providing best execution
considering applicable circumstances. If a third-party manager executes trades
through a broker-dealer other than the one associated with the selected Program,
there will most likely be a commission or mark-up on the trade that wouldn’t
have been charged otherwise.
Clients are encouraged to review the disclosure brochure for the third-party
manager selected for more information regarding their practices.
Limitations due to LPL Licensing/Registration
Supervised Persons that are licensed as registered representatives of LPL
Financial are subject to regulations that restrict them from conducting securities
transactions away from LPL without written authorization. Clients should,
therefore, be aware that for accounts where LPL serves as the Custodian, the
Supervised Person is limited to offering services and investment vehicles that are
approved by LPL and prohibited from offering services and investment vehicles
that may be available through other broker-dealers and custodians.