October 4, 2024.
Dear Client,
In February of 2021, the Washington State Department of Financial Institutions (DFI) made a revision to the list of requirements for Registered Investment Advisors registered in Washington. This change required the inclusion of the following text into a firm’s regulatory documentation.
“...in all instances, the Adviser will send the client a written invoice, including the fee, the formula used to calculate the fee, the fee calculation itself, the time period covered by the fee, and, if applicable, the amount of assets under management on which the fee was based. Also, the Adviser will include the name of the custodian(s) on your fee invoice. The Adviser will send these to the client concurrent with the request for payment or payment of the Adviser’s advisory fees. We urge the client to compare this information with the fees listed in the account statement.”
We were further informed by a State Representative that “if any of the required information is missing from the invoice sent from the custodian, the WA adviser would need to send a supplement invoice that includes the missing information.”
While DFI calls this document a “supplement invoice,” please note that you do not have to take any action as a result of this notice. We have always taken pride in our simple and transparent compensation structure. Your quarterly advisory fees are calculated and collected by our institutional custodian, SEI Private Trust Company.
In the “Transactions” area of your SEI statement, you will find a fee calculation that resembles the following example:
As you can see, this reporting includes specific dates, asset amounts, rates, and calculations. Your specific information will differ from this sample data. For instance our highest rate tier is substantially lower than the 1.25% displayed in this example. Having reviewed this reporting, we have been instructed to provide you with a “general formula” for a quarter’s fee calculation. Our standard fee schedule is as follows:
Having reviewed this reporting, we have been instructed to provide you with a “general formula” for a quarter’s fee calculation. This formula is as follows:
End of Period Market Value x Fee Percentage ÷ 4 = Quarterly Advisory Fee.
Since investment fees are collected quarterly, and in arrears, your most recently assessed fee will appear on your next mailed statement. If you wish to see information about it more immediately, please remember that you can always view the transactions section of your online account information at
We apologize for any confusion that this letter may have caused. Please rest assured that this communication indicates absolutely no change in the costs to you. As stated above, providing you with this supplemental information is now a quarterly requirement of the State of Washington. It is our opinion that this exercise is a waste of paper, postage, time and energy. Please know we make every effort to reduce or eliminate such waste. This is our best effort to adhere to the revised requirements of the Washington DFI. If you have any questions, or if you would prefer to receive future communications of this information electronically, please let us know by telephone or e-mail.
Thank you for your continued confidence and trust.
Sincerely,
Matt Miller, CFP®