Overview
A. Description of the Advisory Firm
B. Types of Advisory Services
year, or the client and spouse had a combined income of $300,000 per year the previous 2
years and expect to do the same the current year. The SEC's definition of Accredited
Investor is put forth in Rule 501 of Regulation D of the Securities Act of 1933. It has
defined Family Offices as qualified clients if they have at least $5 million in assets under
management and are directed by a person who can evaluate merits and risks of
prospective investments. Accredited investors are permitted to invest in alternative
investments but may NOT be charged performance-based fees. The second type are
“qualified clients”, who are clients that have over $1 million invested with us, OR a net
worth of at least $2.1 million, excluding primary residence. Under current regulations,
qualified clients may be charged performance-based fees however, SEM does not do so.
SEM offers the same suite of services to all of its clients. However, specific client financial
plans and their implementation are dependent upon the client Investment Policy
Statement which outlines each client’s current situation
(income, tax levels, and risk
tolerance levels) and is used to construct a client specific plan to aid in the selection of a
portfolio that matches restrictions, needs, and targets.
Clients may impose restrictions in investing in certain securities or types of securities in
accordance with their values or beliefs. However, if the restrictions prevent SEM from
properly servicing the client account, or if the restrictions would require SEM to deviate
from its standard suite of services, SEM reserves the right to end the relationship.
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and any other administrative
fees. SEM does not participate in any wrap fee programs.
SEM has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$1,364,799,575 $0 December 31, 2023
Investment Supervisory Services Fees
SEM’s fee ranges up to 1% of total assets under management per year.
C. Client Tailored Services and Client Imposed Restrictions
D. Wrap Fee Programs
E. Amounts Under Management