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Personal Attention. Independent Advice.

Frequently Asked Questions

Conditions For Managing Accounts
Methods of Analysis, Investment Strategies And Risk of Loss Review of Accounts
Review of Accounts
Investment Discretion
Personal and Proprietary Trading
Brokerage Recommendations
Additional Compensation

Conditions For Managing Accounts

GWM’s investment advisory services are available to high net worth individuals, families, trusts, estates, endowments, charitable organizations, corporations, and profit sharing plans.

For Portfolio Management Services, GWM requires a minimum account size of $1,000,000 — This account minimum may be negotiable based on the length or scope of the client relationship or the nature of the prospective relationship.

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Methods of Analysis, Investment Strategies And Risk of Loss Review of Accounts

GWM uses fundamental, technical, and macro-economic analysis to formulate an investment strategy tailored to each client. GWM uses the following sources of information:

  • Financial Newspapers and Magazines
  • Independent Research Materials
  • Ratings Agency Services
  • Annual Reports
  • Prospectuses
  • Filings with the Securities and Exchange Commission
  • Press Releases.

We work with clients to agree upon the appropriate asset allocation based on the following considerations:

  • Income and liquidity requirements
  • Investment time horizon
  • Risk profile
  • Financial goals
  • Special needs

The investment strategies we use to implement any advice given to clients include the following. Long term purchases (securities held at least one year), short term purchases (securities held less than one year), trading (securities sold within 30 days). GWM may also recommend the use of short sales, margin loans and options investment strategies for the management of our client’s portfolios. Because these types of investment strategies involve additional degrees of risk, they will only be recommended when consistent with the client’s stated investment objectives and tolerance for risk.

GWM implements a disciplined approach to total portfolio management and diversification using the following tools:

  • Exchange-listed Securities
  • Securities Traded Over-The-Counter
  • Foreign Issuers
  • Corporate Debt Securities (Other Than Commercial Paper)
  • Certificates of Deposits
  • Municipal Securities
  • Mutual Fund Shares
  • United States Government Securities
  • Options Contracts on Securities and Commodities
  • Futures Contracts on Tangibles and Intangibles
  • Interests in Partnerships Investing in Real Estate
  • Exchange Traded Funds (ETFs)
  • Structured Products
  • Alternative Investments
  • Foreign Exchange
  • High Frequency Trading Algorithms

Recommendations for new investments in accounts managed by GWM will typically be limited to the above items and any investments transferred into the managed account. Non-security classes of investments, e.g., futures and commodities, involve certain additional degrees of risk, they will be recommended and managed only when consistent with a client’s stated investment objectives and tolerance for risk.

Investing in securities involves risk of loss that clients should be prepared to bear.

GWM is comfortable investing across the full breadth of the market. However, the backbone of many of our investment portfolios has increasingly been supported by the use of Exchange Traded Funds (ETFs). ETFs are extremely liquid as well as cost and tax efficient.

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Review of Accounts

Accounts managed by GWM are monitored on a regular basis and reviewed on at least a quarterly basis by the clients Adviser. Accounts are reviewed for consistency with the individual client’s objectives. More frequent reviews may be triggered by changes in the client’s needs and circumstances, the client’s risk tolerance, by events related to the issuer of a security, or by market, economic or political events. We offer to meet with clients monthly.

Financial plans are reviewed and approved (as needed) before being submitted to a client by Michael Freeburg or Daniel Sullivan, Chief Compliance Officer. In addition, Daniel Sullivan periodically reviews GWM client accounts for a variety of reasons:

Daily – review trade blotter
Annually – to ensure investment objectives are being met
Miscellaneous – per client instruction, or with change in investment objectives

Third Party Investment Managers and the accounts managed by them will be reviewed by the clients Adviser on a quarterly basis or as otherwise agreed upon at the inception of the client agreement.

In addition, GWM will review each client account that incurs a portfolio loss in excess of 10% +/- over the course of certain periods.

For accounts managed by GWM on the Interactive Brokers Trader Workstation (TWS) platform, daily account statements, which include position and transaction information, are available to clients over the Internet. Clients are primarily responsible for requesting the account statements through the TWS platform; however, GWM will download and send an account statement upon request.

A report from TWS will include: Net Asset Value Time Series, Mark-to-Market Performance Summary in Base, Realized and Unrealized Performance Summary in Base, Cash Report, Change in Position Value, Long Open Positions, Trades, Other Fees, Deposits and Withdrawals, Interest Accruals, Broker Interest Paid, Security Information, Codes, and Legal Notes.

For clients with accounts on a custodial platform other than TWS, the types of reports and the frequency with which the reports are provided will depend on the platform. GWM will at the inception of any account relationship that directs the use of a platform other than TWS advise the client of the types of reports and the frequency with which such reports will be provided to the client.

In addition, GWM will provide performance reports on a quarterly or monthly basis, as agreed upon.

GWM creates excel driven portfolio summary’s for our clients. These portfolio summaries may provide a single account overview or an aggregated account overview depending on the client. The portfolio summary generally discloses basic account information such as beginning and ending balance, geometric linking performance, deposits and withdrawals, performance vs. benchmarks as well as asset allocation. These portfolio summaries are generally delivered monthly. These portfolio summaries are not a substitute for custodial account statements. These summaries have a disclosures page with all pertinent disclosures.

For Third Party Investment Manager and Monitoring Services, the types of reports and the frequency of reporting will be as contracted for.

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Investment Discretion

GWM manages advisory accounts on a discretionary or nondiscretionary basis. Each client will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Clients sign a Client agreement granting discretionary authority.

For clients whose accounts are managed by GWM through the TWS platform of IB, GWM must be provided with discretionary trading authority to affect trades in the client’s account. The client will retain the right to direct GWM to affect trades in the client’s account.

Clients always retain individual ownership of all securities.

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Personal and Proprietary Trading

GWM has adopted a Code of Ethics (COE) expressing the firm’s commitment to ethical conduct. GWM’s COE describes the firm’s fiduciary duties and responsibilities to clients, and sets forth GWM’s practice of supervising the personal securities transactions of supervised persons with access to portfolio recommendations and transactions. All individuals associated with GWM have read and are expected to comply with the COE. In addition, our COE governs personal trading.

To supervise compliance with its COE, GWM requires that anyone associated with this advisory practice, with access to advisory recommendations or transactions provide initial and annual securities holdings reports and quarterly securities transactions reports to the firm’s Chief Compliance Officer. These reports are reviewed quarterly. GWM requires such persons to receive approval from the Chief Compliance Officer prior to investing in any IPO’s or private placements (limited offerings).

GWM requires that all individuals act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. GWM’s COE further includes the firm’s policy prohibiting the use of material non-public information. Any individual not in observance of the above will be subject to discipline and or termination.

GWM will provide a copy of its COE to any client or prospective client upon request.

GWM requires all employees to read the COE and sign an acknowledgement statement that they will abide by the GWM COE.

GWM has no material, financial interest in securities in which clients might invest.

GWM related persons may buy or sell securities for their personal accounts identical to or different than those recommended to clients. It is the expressed policy of GWM that no person employed by GWM shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on the investment decisions of advisory clients.

This Code establishes rules of conduct for all supervised persons of GWM and is designed to, among other things; govern personal securities trading activities in the accounts of employees. The Code is based upon the principle that GWM, and its employees owe a fiduciary duty to GWM’s clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid serving their own personal interests ahead of clients, taking inappropriate advantage of their position with the firm and any actual or potential conflicts of interest or any abuse of their position of trust and responsibility.

The Code is designed to ensure that the high ethical standards long maintained by GWM, continue to be applied. The purpose of the Code is to preclude activities, which may lead to or give the appearance of conflicts of interest, insider trading and other forms of prohibited or unethical business conduct. The excellent name and reputation of our firm continues to be a direct reflection of the conduct of each employee and supervised person.

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Brokerage Recommendations

As an SEC Registered Investment Advisory firm GWM has a fiduciary responsibility to seek best execution for client transactions. GWM generally uses Trader Workstation (“TWS”) platform offered to investment advisors by Interactive Brokers, LLC, a registered broker dealer and FINRA member. Clients are not under any obligation to effect trades through TWS. GWM will endeavor to accommodate specific client requests to custody assets at another broker dealer.

GWM has reviewed the TWS platform and recommends TWS based on a number of factors. These factors include the financial strength of the broker dealer, the broker’s transaction confirmation and account statement practices, trade clearance and settlement capabilities. Other factors include GWM’s experience with TWS, the broker’s reputation, and the quality of execution services available through TWS including state of the art Smart order routing and low transaction and custodial costs available through Interactive Brokers.

As a fiduciary, GWM has the responsibility to effect orders correctly, promptly and in the best interests of our clients. In the event any error occurs in the handling of any client transactions due to GWM’s actions, or inaction, or actions of others, GWM’s policy is to seek to identify and correct any errors as promptly as possible without disadvantaging the client or benefiting GWM in any way.

If the error is the responsibility of GWM, any client transaction will be corrected and GWM will be responsible for any client loss resulting from an inaccurate or erroneous order.

GWM’s policy and practice is to monitor and reconcile all trading activity, identify and resolve any trade errors promptly, document each trade error with appropriate supervisory approval and maintain a trade error file.

If a trade error results in a profit to an unintended client account, at the cost of another GWM client account, an offsetting financial transaction will be used to rectify the aggrieved party. The end result will be that no client benefits or suffers as a result of the error.

GWM’s financial advisers may also be registered brokers with Private Client Services, LLC, however, GWM does not custody advisory client accounts at Private Client Services, LLC. Under certain circumstances Advisory clients may wish to establish a brokerage relationship through Private Client Services, LLC, Inc, this determination is made on a case-by-case basis.

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Additional Compensation

GWM is primarily a fee-based financial advisory and portfolio management firm.

Fee Structure

The annual fee for Portfolio Management Services will be based on a percentage of assets under management, according to the schedule below:

Client Assets Under Management

Maximum Annual Fee (%) First $1,000,000 1.25
Next $3,000,000 1.00
Over $5,000,000 0.90

General Information on Services and Fees

In certain circumstances, fees may be negotiable. GWM may charge different clients receiving the same services different fees. The above is the firm’s standard fee schedule.

The annual fee for portfolios will be determined on a sliding scale and based on the amount of assets under management and the level of client services.

Clients should note that GWM has pre-existing client relationships with historical fee arrangements, which may not be offered to prospective clients.

Depending on the custodial platform, either GWM or the custodian will calculate the advisory fee based on the value of the assets held in the client’s account and the annual rate.

GWM generally uses Interactive Brokers, LLC (IB) as custodian for client assets. For clients who utilize IB the advisory fee will be calculated based on the value of the assets held in the client’s account at the end of each business day. The daily fee will be equal to the annual fee divided by the number of business days in the calendar year.

Other Custodial Platforms: For clients who direct the use of a custodial platform other than IB, the method by which the fee will be calculated and charged will depend on the platform and on client preference.

GWM will endeavor to accommodate the billing preferences of the client within the options available on any such platform, and will afford the client the option of paying the advisory fee separately from the custodian.

Third Party Investment Manager and Monitoring Services: GWM may provide Third Party Investment Management and Monitoring Services. The client will be billed directly on an annual basis after services are rendered. The fee for this service is 0.25%, this fee is negotiable. Third party managers may charge a separate fee, which will be disclosed to the client in the third party managers ADV. GWM does not receive any compensation based on the performance or capital gains of any client account.

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