Guru Q & A Archive
Browse previous questions from Advisers and the Gurus' responses. The answer to your current question might just be found here!
Negotiable Fee Schedules [Word Doc]
Question: In response to Item 1 of ADV Part II, may an investment adviser which charges for its services in accordance with a fee schedule, but which also permits negotiation of fees, simply set forth the basic fee schedule and state that its fees are negotiable, or must the adviser disclose the range within which fees can be negotiated?
Response: The extent of disclosure required by Item 1 of ADV Part II concerning the adviser's fees will depend on the facts and circumstances. As a general matter, if an adviser's usual fees are negotiable, but only within a range, the adviser would have to disclose his basic fee schedule, as well as the range within which fees can be negotiated. On the other hand, if fees are negotiable, but no particular range has been established either explicitly or by practice, a general statement that fees are negotiable, together with the inclusion of the basic fee schedule, generally would be adequate.
General Q & A [Word Doc]
Information regarding assets under management, solicitors, national de minimis standards,etc.
Balance Sheet - Cash or Accrual Basis? [Word Doc]
Written Policies and Procedures out of date? [Word Doc]
Q: I run a relatively simple and small-medium sized investment advisory firm. It is time to review our firm's written supervisory policies and procedures, which are drastically out of date. Any suggestions as to the type of content I should have?
A: We have included here a proposed sample table of contents for the type of firm you describe. Your firm may have unique services, material affiliations and other material information that may result in more comprehensive policies and procedures, but this sample should get you started. We hope this is helpful.
Automatic Payment of Fees Deemed Custody? [Word Doc]
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