Preliminary Request for Public Comment on Proposed Fee Table for State-Registered Investment Advisers

June 26, 2018 - Daniel J. Traub

Subject: Fee Table comment
From: Daniel J. Traub
June 26, 2018

A fee table makes sense.  A few thoughts occur to me:

  • I would certainly offer it to potential and new clients.  But I don’t think it really needs to be sent each year to existing client (i.e. like the Privacy Policy).  Should just be included as an offer much like the annual offer for current ADV.  Of course if there is a change in the fee structure that should certainly be sent at the time of the change.

  • For advisors that charge a fee as a percent of assets under management the proposed table will not accurately detail the fees.  The reason is that most advisors I know charge a lower rate as the amount of money under management rises (i.e 1% for first $1mm, 0.8% for the next $1.5mm, etc).  The proposed table does not leave room for this.

  • I think there is a problem when you lump together investment advisory fees in the same table as fees for other items such as financial planning.  One table could cover investment advisory fees.  A second table can cover fees for other services (such as financial planning)

Daniel J. Traub
Tempo Financial Advisors, LLC