Looking for a Sec Forms And Templates? Download it for free!

SEC File Number:

Schedule H of

Applicant:

Date:

Form ADV

801-

Page 2

(d) a statement that the program may cost the client more or less than purchasing such services separately and a statement

of the factors that bear upon the relative cost of the program (e.g., the cost of the services if provided separately and the

trading activity in the client’s account);

(e) if applicable, a statement that the person recommending the program to the client receives compensation as a result of the

client’s participation in the program, that the amount of this compensation may be more than what the person would receive

if the client participated in other programs of the sponsor or paid separately for investment advice, brokerage, and other

services, and that the person may therefore have a financial incentive to recommend the wrap fee program over other

programs or services;

(f) a description of the nature of any fees that the client may pay in addition to the wrap fee and the circumstances under which

these fees may be paid (including, if applicable, mutual fund expenses and mark-ups, mark-downs, or spreads paid to

market makers from whom securities were obtained by the wrap fee broker);

(g) how the program’s portfolio managers are selected and reviewed, the basis upon which portfolio managers are

recommended or chosen for particular clients, and the circumstances under which the sponsor will replace or recommend

the replacement of the portfolio manager;

(h) (1) if applicable, a statement to the effect that portfolio manager performance information is not reviewed by the sponsor

or a third party and/or that performance information is not calculated on a uniform and consistent basis,

(2) if performance information is reviewed to determine its accuracy, the name of the party who reviews the information

and a brief description of the nature of the review,

(3) a reference to any standards (i.e., industry standards or standards usely solely by the sponsor) under which performance

information may be calculated;

(i) a description of the information about the client that is communicated by the sponsor to the client’s portfolio manager, and

how often or under what circumstances the sponsor provides updated information about the client to the portfolio manager;

(j) any restrictions on the ability of clients to contact and consult with portfolio managers;

(k) in narrative text, the information required by Items 7 and 8 of Part II of this form and, as applicable to clients of the wrap

fee program, the information required by Items 2, 5, 6, 9A and C, 10, 11, 13 and 14 of Part II;

(l) if any practice or relationship disclosed in response to Item 7, 8, 9A, 9C and 13 of Part II presents a conflict between the

interests of the sponsor and those of its clients, explain the nature of any such conflict of interest; and

(m) if the sponsor or its divisions or employees covered under the same investment adviser registration as the sponsor act as

portfolio managers for a wrap fee program described in the brochure, a brief, general description of the investments and

investment strategies utilized by those portfolio managers.

8. Organization and Cross References. Except for the cover page requirements in Item 7(a) above, information contained in

the brochure need not follow the order of the items listed in Item 7. However, the brochure should not be organized in such

a manner that important information called by the form is obscured.

Set forth below the page(s) of the brochure on which the various disclosures required by Item 7 are provided.

Page(s)

Item

7(a)

cover

Item

7(f)

Item

7(j)

#7(b)

#7(g)

#7(k)

#7(c)

#7(h)

#7(l)

#7(d)

#7(i)

#7(m)

#7(e)

Form Sec 1707 - Uniform Application For Investment Adviser Registration - Securities And Exchange Commission Page 45

Related Articles

Related forms

Related Categories