Our firm manages assets for many different types of clients to help meet their financial goals while
remaining sensitive to risk tolerance and time horizons. As a fiduciary it is our duty to always act in
the client’s best interest. This is accomplished in part by knowing the client. Our firm has established
a service-oriented advisory practice with open lines of communication. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Our wrap fee program allows clients to pay a single fee for investment advisory services and
associated custodial transaction costs. Because our firm absorbs client transaction fees, an incentive
exists to limit trading activities in client accounts. Custodial transaction costs, however, are not
included in the advisory fee charged by our firm for non-wrap services, and are to be paid by the
client to their chosen custodian. Depending on the client’s account or portfolio trading activity, clients
may pay more for using our wrap fee services than they would for using our non-wrap services.
Our recommended custodian, Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees
for U.S. listed equities and exchange traded funds. Since we pay the transaction fees charged by the
custodian to clients participating in our wrap fee program, this presents a conflict of interest because
we are incentivized to recommend equities and exchange traded funds over other types of securities
in order to reduce our costs.
Our Wrap Advisory Services
Wrap Portfolio Management:
As part of our Wrap Portfolio Management services, Clients may be provided with standalone asset
management or a combination of asset management and financial planning or consulting services.
This service is designed to assist clients in meeting their financial goals through the use of a financial
plan or consultation. Our firm conducts client meetings to understand their current financial
situation, existing resources, financial goals, and tolerance for risk. Based on what is learned, an
investment approach is presented to the client that may consist of individual stocks, bonds, Exchange
Traded Funds (“ETFs”), options, mutual funds and other public and private securities or investments.
Once the appropriate portfolio has been determined, portfolios are continuously
and regularly
monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and
objectives. Upon client request, our firm provides a summary of observations and recommendations
for the planning or consulting aspects of this service.
Fee Schedule:
The maximum annual fee charged for this service will not exceed 1.90%. Fees to be assessed will be
outlined in the advisory agreement to be signed by the Client. Annualized fees are billed on a pro-
rata basis monthly in advance based on the value of the account(s) on the last day of the previous
month. Adjustments are made for deposits and withdrawals made during the month. In rare cases,
our firm will agree to directly invoice. Fees are negotiable and will be deducted from client
account(s). As part of this process, Clients understand the following:
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 FLC Capital Advisors
a) The client’s independent custodian sends statements showing the market values for each
security included in the Assets and all account disbursements, including the amount of the
advisory fees paid to our firm; and
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian.
Other Types of Fees & Expenses:
In addition to our advisory fees above, Clients may also pay holdings charges imposed by the chosen
custodian for certain investments, fees for trades executed away from the custodian listed in Item 9
of this Brochure, wire transfer fees, fees and taxes on brokerage accounts and securities transactions,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups
and mark-downs, spreads paid to market makers, 12b-1 fees, surrender charges, IRA and qualified
retirement plan fees. Our firm does not receive a portion of these fees.
Terminations & Refunds:
Either party may terminate the advisory agreement signed with our firm for Wrap Portfolio
Management service in writing at any time. Upon notice of termination, our firm will process a pro-
rata refund of the unearned portion of the advisory fees charged in advance.
Wrap Fee Program Recommendations:
Our firm does not recommend or offer the wrap program services of other providers.