Introduction This Brochure describes the investment advisory services by the Digital Advisory Solutions group (“DAS”)
of Goldman Sachs & Co. LLC (“GS&Co.”). DAS provides advisory services to individuals and helps
clients build and preserve their financial wealth through its technology platform. DAS’s services are
available through its websites www.honestdollar.com and invest.goldman.com and its mobile applications
(collectively, the “Site”). Unless otherwise specified, references in this Brochure to “clients” mean DAS
clients and references to the advisory services provided by GS&Co. mean the advisory services provided
by DAS.
GS&Co.’s principal owner is The Goldman Sachs Group, Inc., a publicly traded bank holding company
and financial holding company under the Bank Holding Act of 1956, as amended (“BHCA”), and a
worldwide, full-service financial services organization. GS&Co. has been a registered investment adviser
with the U.S. Securities and Exchange Commission (“SEC”) since 1981. The Goldman Sachs Group, Inc.,
GS&Co. and their respective affiliates, directors, partners, trustees, managers, members, officers and
employees are referred to collectively as “Goldman Sachs.”
Program Description DAS offers individuals the ability to open investment advisory accounts (“Advisory Accounts”) for
themselves individually, including Traditional Individual Retirement Accounts (“IRA”), Roth IRAs, and, in
the case of a self-employed individual or independent contractor, a Simplified Employee Pension (“SEP”)
IRAs (collectively, “Retirement Accounts”), as well as jointly with other individuals through an online
platform (the “Program”). The Program is designed to provide a way for individuals to regularly invest
money and access DAS’s advisory services, along with brokerage and custody services, for a single fee.
The number and type of Advisory Accounts that an individual can open under the Program may be limited
based on the channel by which that individual accessed the Program. The Program was previously
offered by GS&Co.’s affiliate, Honest Advisors, LLC (“Honest Advisors”), which assigned its client
agreements to GS&Co. in September 2018.
The Program provides investment advice and delivers advisory services to clients primarily through the
Portfolio Recommendation Tool (as defined below) and the Site, and does not generally provide
investment advice in person, over the phone, in live chat, or in any other manner other than through the
advisory services available on the Site.
Clients establish Advisory Accounts and enter into an agreement with a financial institution (the
“Custodian”) designated by DAS appointing the Custodian to serve as custodian with respect to their
Advisory Accounts and provide the client with brokerage services. With respect to Retirement Accounts,
the Custodian will also act as the client’s IRA custodian. The Custodian will establish and carry an
account that holds the client’s cash and securities and records the transactions in such account. Subject
to the terms of its agreement with the Custodian, DAS may remove or replace the Custodian at any time.
The current Custodian is Apex Clearing Corporation (“Apex”), a New York corporation. Apex is a
registered broker-dealer that is not affiliated with GS&Co. or its affiliates.
Portfolio Recommendation and Management The Program is designed to prompt investing and saving behaviors and provide access to portfolios that
invest through exchange-traded funds (“ETFs”) that track indices. Through the Program, DAS offers
model portfolios developed by GS&Co.’s Investment Strategy Group (“ISG”) that are designed to allocate
assets among ETFs representing different asset classes. DAS is currently using Portfolios that invest in
unaffiliated ETFs, as well as cash, held as a free credit balance by the Custodian. ISG’s model
construction process is designed to offer multi-asset class portfolios that are diversified across asset
classes, regions, and the risk spectrum. In its role as sponsor of the Program, DAS does not manage the
underlying ETFs. However, DAS reserves the right to change, in its sole discretion and from time to time,
without prior notice to clients: (i) the number of Portfolios that it deems appropriate to address the
investment objectives, investment time horizons, and risk tolerances of its clients; (ii) the selection of the
ETFs that comprise each of the Portfolios; and (iii) the relative weightings of the ETFs and cash within
each of the Portfolios. DAS further reserves the right, in its sole discretion and from time to time, upon
providing prior notice to clients, to utilize model portfolios constructed by affiliates or third parties (“Model
Providers”), and to make additional Model Providers available through the Program. Through the
Program, DAS does not currently offer affiliated ETFs or other affiliated investment products. In the
future, DAS may offer affiliated ETFs and other affiliated investment products through the Program.
The Program uses an algorithm that functions as a portfolio recommendation tool (the “Portfolio
Recommendation Tool”) to recommend a Portfolio based on certain information that a client provides
through the Site (the “Suggested Portfolio”). While DAS’s investment advisory personnel oversee the
current operation of, and are responsible for any enhancements to, the Portfolio Recommendation Tool’s
algorithm, such personnel do not override the Portfolio Recommendation Tool’s algorithm to recommend
a different Suggested Portfolio to any particular client, whether based on any additional criteria (including,
without limitation, current market conditions) or otherwise. Clients should understand that the Portfolio
Recommendation Tool currently relies on the client’s investment time horizon and risk tolerance for each
Advisory Account maintained by the client in recommending a Suggested Portfolio. Clients who
previously enrolled in the Program prior to consideration of this particular combination of factors may
update their investment profile and, if applicable, select a new Portfolio for any of their Advisory Accounts.
The Portfolio Recommendation Tool asks a series of questions to assess a client’s current age and
liquidity needs as well as their investment time horizon and risk tolerance for each Advisory Account in
connection with the account opening process. The Portfolio Recommendation Tool does not consider the
entire range of information a client provides for purposes of recommending a Suggested Portfolio. DAS
uses the information clients provide through the Site regarding liquidity to make an initial determination
whether the Program is appropriate for the client. The Portfolio Recommendation Tool only considers the
answers to the questions regarding investment time horizon and risk tolerance for each Advisory Account,
the values for which are weighted in accordance with DAS’s methodology (which does not weight them
equally) and are then mapped to one of various Suggested Portfolios which is recommended to the client.
Clients are not bound by the Suggested Portfolio recommended by the Portfolio Recommendation Tool
and may, at the time when they initially receive a Suggested Portfolio, select either of the Portfolios
adjacent to the Suggested Portfolio on the risk spectrum of Portfolios available through the Program.
Clients may cause the Portfolio Recommendation Tool to generate a new Suggested Portfolio for a
particular Advisory Account at any time by revising the information they provide through the Site. The
Portfolio Recommendation Tool is solely responsible for determining which of the Portfolios available in
the Program to recommend to each client based on certain information provided by such client. Clients
who maintain multiple Advisory Accounts may receive different Suggested Portfolios from the Portfolio
Recommendation Tool for such Advisory Accounts if the client provides different information regarding
investment time horizon and risk tolerance for each Advisory Account.
The selection and relative weighting of the ETFs in each of the Portfolios has been designed by ISG to
pursue specific investment objectives, including diversification. Although clients may select a different
Portfolio for a particular Advisory Account at any time, subject to certain limitations, they are not able to
change the underlying ETFs that comprise each Portfolio, except by requesting a reasonable investment
restriction on the management of their Advisory Accounts. Clients may request an investment restriction
for an Advisory Account by contacting us as follows: if you utilize the GS Site, call 1-833-474-6837 or
sending an e-mail to support@invest.goldman.com, if you utilize the HD Site, call 1-855-783-7283 or
send an e-mail to support@honestdollar.com. DAS is solely responsible for determining whether the
restriction is reasonable. DAS may, in its discretion, hold the amount that would be invested in the
restricted security in cash, invest in substitute securities, or invest it on a pro rata basis across the other
securities in the Portfolio that are not restricted. Clients should be aware that the performance of an
Advisory Account with restrictions will differ from, and may be lower than, the performance of Advisory
Accounts without restrictions. As part of Goldman Sachs, a global financial services organization that is
subject to a number of legal and regulatory requirements, GS&Co. is subject to, and has itself adopted,
internal guidelines, restrictions and policies that may restrict investment decisions and activities on behalf
of Advisory Accounts under certain circumstances. See Item 9, Additional Information.
The Portfolio a client ultimately selects, taking into account any reasonable investment restrictions, is the
client’s selected Portfolio (the “Selected Portfolio”), and all investment transactions are executed with the
goal of aligning the holdings of the Advisory Account with the Selected Portfolio’s target allocation,
including by rebalancing, as further described below. Clients may change their Selected Portfolio for an
Advisory Account at any time by revising the information they submit through the Site and thereby
causing the Portfolio Recommendation Tool to generate a new Suggested Portfolio for that Advisory
Account, but they may not have more than one Selected Portfolio for an Advisory Account. Clients are
solely responsible for the decision to invest in their Selected Portfolio. Clients should carefully review and
consider the information available on our Site about the Suggested Portfolio as well as any other
Portfolios made available to the client and their constituent ETFs before choosing a Selected Portfolio for
an Advisory Account. Clients who choose a Selected Portfolio other than the Suggested Portfolio should
understand that such a Selected Portfolio may not be suitable based on their risk tolerance and
investment time horizon, and that the Selected Portfolio may perform worse for the client over any time
period than the Suggested Portfolio or any other investment.
Under the terms of the Investment Advisory Agreement with DAS that governs the client’s Advisory
Account (the “Client Agreement”), clients authorize the rebalancing of holdings and acknowledge that any
dividends will be received in cash and invested in accordance with the client’s Selected Portfolio as part
of the rebalancing process. The Advisory Accounts are monitored by DAS’s portfolio management
system (“PM System”) to determine if the holdings have drifted beyond a pre-determined percentage from
the target allocation and that the Advisory Accounts are otherwise eligible to trade. DAS will review such
deviations and will periodically rebalance the Advisory Accounts to bring the holdings back into line with
the Selected Portfolio. The rebalancing process is effected through the PM System, and rebalancing
orders are reviewed and initiated by DAS’s investment advisory personnel. Advisory personnel have the
ability to override or delay rebalancing in the event of volatile market conditions or other circumstances
that DAS determines may negatively affect Advisory Accounts. DAS may, at any time and in its sole
discretion, modify the manner or frequency with which rebalancing occurs. Clients should understand
that there is no guarantee that the holdings in their Advisory Account will match the allocations of their
Selected Portfolio at all times, and that various factors (including the timing and frequency of deposits and
withdrawals, market volatility and disruptions, the timing and frequency of a client’s choice of or changes
to their Selected Portfolio, reasonable restrictions, access interruptions, and hardware or software
failures) can impact the extent to which holdings in a client’s Advisory Account will replicate the Selected
Portfolio at any particular point in time. The Program includes strategic asset allocation models that are
based on DAS’s long-term view. The Program does not provide tactical advice and clients should not
expect to see tactical changes to their Selected Portfolios in response to market movements or market
volatility events.
The ETF shares purchased or sold on behalf of a client and held in a client Advisory Account may be
either whole shares or fractional shares, depending upon the amounts a client contributes to its Advisory
Account. To the extent that DAS trades fractional shares of any ETF on behalf of Program clients, it does
so by allocating any excess fractional shares to the Custodian’s fractional facilitation account, and the
Custodian in turn accumulates fractional shares and manages their fractional facilitation account through
trades in whole share quantities in accordance with their own policies as they pertain to management of
such accounts and positions. DAS and the Custodian each reserves the right, at any time and each in its
sole discretion, without prior notice to Program clients, to change the details of the policies and
procedures governing the mechanics of trading fractional shares, including, without limitation, allocation
calculation and rounding procedures. Fractional shares are typically unrecognized and illiquid outside of
a client’s Advisory Account and, as a result, fractional shares may not be marketable or transferrable to
another brokerage account. In the event of a liquidation or transfer of the assets in a client’s Advisory
Account to another account, DAS may convert such fractional shares to cash. Dividends received in
connection with assets in a client’s Advisory Account will be allocated pro-rata based on the fractional
shares held and clients will not receive a dividend if the pro-rata amount of such dividend is less than
$0.01.
Risk Factors This Brochure does not include every potential risk associated with the Program, or all of the risks
applicable to a particular Advisory Account. Rather, it is a general description of certain risks inherent in
the Program. Clients should refer to their Client Agreement and the underlying prospectuses for the
ETFs offered through the Program for additional information.
Clients should understand that all investment strategies and the investments made when
implementing those investment strategies involve risk of loss and clients should be prepared to
bear the loss of assets invested. The investment performance and the success of any investment
strategy or particular investment cannot be predicted or guaranteed, and the value of a client’s
investments fluctuates due to market conditions and other factors. The investment decisions
made and the actions taken for Advisory Accounts are subject to various market, liquidity,
currency, economic, and political risks, and will not necessarily be profitable. The types of risks
to which an Advisory Account is subject, and the degree to which any particular risks impact an
Advisory Account, may change over time depending on various factors, including the investment
strategies, investment techniques and asset classes utilized by the Advisory Account, the timing
of the Advisory Account’s investments, prevailing market and economic conditions, reputational
considerations, and the occurrence of adverse social, political, regulatory or other developments.
Past performance of Advisory Accounts is not indicative of future performance.
•
Asset Allocation and Rebalancing Risk – The risk that an Advisory Account’s assets may be out
of balance with the Selected Portfolio allocation. Any rebalancing of such assets may be
infrequent and, even if achieved, may have an adverse effect on the performance of the Advisory
Account’s assets. The rebalancing process is currently effected through the PM System, which is
overseen manually by DAS’s investment advisory personnel who have the ability to override the
system’s determination whether to rebalance under certain circumstances, and is thus subject to
both technological and human error.
•
Cybersecurity Risk – The risk of actual and attempted cyber-attacks, including denial-of-service
attacks, harm to technology infrastructure and data from misappropriation or corruption, and
reputational harm. Due to Goldman Sachs’ interconnectivity with third-party vendors, central
agents, exchanges, clearing houses, and other financial institutions (including the Custodian),
Goldman Sachs, and thus indirectly the Advisory Accounts, could be adversely impacted if any of
them is subject to a cyber-attack or other information security event. Although Goldman Sachs
takes protective measures and endeavors to modify them as circumstances warrant, its computer
systems, software, and networks may be vulnerable to unauthorized access, misuse, computer
viruses or other malicious code, and other events that could have a security impact, or render
Goldman Sachs unable to transact business on behalf of Advisory Accounts.
•
Diversification Risk – The risk that the Program assumes the beneficial nature of diversification.
While using a diversified portfolio to reduce risk is a widely accepted investment principle,
diversification cannot reduce risk to zero, and the returns on a diversified portfolio during any
given time period may be lower than the returns on one or more investments concentrated in an
industry, sector, or geographic region that was profitable during that time period.
•
Equity and Equity-Related Securities and Instruments Risk – The value of common stocks
of U.S. and non-U.S. issuers may be affected by factors specific to the issuer, the issuer’s
industry and the risk that stock prices historically rise and fall in periodic cycles.
•
ETF Investment Risk – The risk that: (i) ETFs may trade at a discount or premium to their
underlying net asset value (“NAV”); (ii) ETFs may not fully track the market segment or index
that underlies their investment objective, resulting in performance that differs from
expectations; (iii) investors purchasing an ETF at a premium may underperform the ETF
NAV, while the redemption of shares may result in the ETF trading at a discount to NAV;
(iv) an active trading market for an ETF’s shares may not develop or be maintained; and
(v) the requirements of the exchange necessary to maintain the listing of an ETF will be
changed or otherwise not met.
•
Frequent Trading and Portfolio Turnover Rate Risks – The risk that high turnover and frequent
trading in an Advisory Account could result in, among other things, higher transaction costs and,
to the extent applicable, adverse tax consequences.
•
Hypothetical Performance and Projected Returns – The risk arising from reliance on hypothetical
performance information and projected returns. Projected returns are hypothetical, do not reflect
actual investment results, and are not guarantees of future results. Such projected performance
is subject to a number of limitations and assumptions designed to determine the probability or
likelihood of a particular investment outcome based on a range of possible outcomes. It is
possible that any of those assumptions, including retirement age, may prove not to be accurate.
In addition, performance of the Suggested Portfolio, a client’s Selected Portfolio, other Portfolios,
or a client’s Advisory Account may differ materially from investment gains and avoidance of
investment losses projected, described, or otherwise referenced in forward-looking statements,
and the projected returns associated with any Portfolio may not materialize.
•
Index/Tracking Error Risks – The risk that the performance of an Advisory Account that tracks an
index may not match, and may vary substantially from, the index for any period of time and may
be negatively impacted by any errors in the index, including as a result of an Advisory Account’s
inability to invest in certain securities as a result of legal and compliance restrictions, regulatory
limits or other restrictions applicable to the Advisory Account, reputational considerations or other
reasons. As an index may consist of relatively few securities or issuers, tracking error may be
heightened at times when an Advisory Account is limited by restrictions on investments that the
Advisory Account may make.
•
Limited Nature of the Portfolio Recommendation Tool and PM System – In addition to the risks
described in “Cybersecurity Risk” above and “Limited Nature of the Program” and “Reliance on
Data Risk” below, the use of algorithms such as the ones underlying the Portfolio
Recommendation Tool and PM System to provide investment advisory services carries the risk
that changes to the algorithm’s code, although subject to compliance controls and testing, may
not have the desired effect with respect to client accounts. While this risk increases if changes to
an algorithm are insufficiently tested prior to implementation, even extensively tested changes
may not produce the desired effect over time. The Portfolio Recommendation Tool uses a limited
universe of inputs to recommend a Suggested Portfolio for each Advisory Account maintained by
a client from a limited universe of possible outputs. In particular, the Portfolio Recommendation
Tool currently recommends a Suggested Portfolio based on a client’s responses to questions
relating to investment time horizon and risk tolerance for a particular Advisory Account, in each
case as provided by the client through the Site, and does not verify the completeness or accuracy
of such information or consider any information regarding outside assets, concentration, debt, or
other accounts a client may have with GS&Co., any of its affiliates, or with any third party. The
Portfolio Recommendation Tool uses this information regarding the client’s investment time
horizon and risk tolerance for a particular Advisory Account to recommend a Suggested Portfolio
for that Advisory Account from a limited number of asset allocation models, profiles, and
underlying instruments. The Portfolio Recommendation Tool assumes that each combination of
relevant responses either maps to one of the Portfolios available in the Program or means that
such client should be prevented from opening an Advisory Account. The Portfolio
Recommendation Tool does not take into account changes in market conditions, and DAS does
not override the Portfolio Recommendation Tool’s recommendation of a Suggested Portfolio
under any circumstances, whether due to market conditions or otherwise, although each client
may, subject to the procedures and limitations described above, select a different Portfolio for an
Advisory Account. The functionality of the PM System is partly dependent upon information
provided by the Custodian, third parties, and other external sources, meaning that performance of
the PM System could be impacted by issues with the delivery or the accuracy of the information
provided.
•
Limited Nature of the Program – The risk arising from the limited nature and scope of the
Program. The Program is designed to offer individuals the ability to invest in Advisory Accounts
by providing a simple, efficient solution. The Program does not provide comprehensive financial
or tax planning or legal advice unless explicitly agreed to in writing between you and GS&Co.,
and clients are advised and afforded the opportunity to seek the advice and counsel of their own
tax, financial, and legal advisers. Neither GS&Co. nor any of its affiliates is responsible for
establishing or maintaining any Advisory Account’s compliance with the requirements of the
Internal Revenue Code for a Traditional IRA, Roth IRA, SEP IRA, or any other type of account
that may be offered through the Program or determining any client’s individual tax treatment
regarding such account. Furthermore, neither GS&Co. nor any of its affiliates is responsible for
withholding any tax penalties that may apply to clients’ accounts or for any state or federal
income tax withholding, except as may otherwise be required by applicable law. DAS’s
recommendations are limited based on the information clients provide through the Site and the
Program’s use of the Portfolio Recommendation Tool, the limitations of which are further
discussed above. Clients should take into consideration the limited nature of the Program in
evaluating the investment advice and recommendations provided through the Site. Furthermore,
the Program: (a) is not a complete investment program; (b) does not account for multiple
investment goals within an Advisory Account; (c) does not consider outside assets,
concentration, debt, or other accounts a client may have with GS&Co., any of its affiliates, or with
any third party; (d) offers a limited number of asset allocation models, profiles, and underlying
instruments; (e) is not suitable for all investors; and (f) relies on the information provided by
clients in providing investment advice, and does not verify the completeness or accuracy of such
information. There could be one or more products available in the investment community that are
more appropriate than the investment products made available through the Program. Given the
inherent limitations of the Program, clients should carefully consider whether the Program is the
right investment solution for their needs.
•
Low Trading Volume Risk – The risk that a client may not be able to monetize his/her investment
or will have to do so at a loss as a result of generally lower trading volumes of the securities
compared to other types of securities or financial instruments.
•
Market/Volatility Risk – The risk that the value of the assets in which an Advisory Account invests
may decrease (potentially dramatically) in response to the prospects of individual companies,
particular industry sectors or governments, changes in interest rates, and national and
international political and economic events and policies due to increasingly interconnected global
economies and financial markets.
•
Model Portfolio Risk – The management of a client’s Advisory Accounts by DAS in its advisory
capacity includes the use of various quantitative or investment models –the Portfolios. There may
be deficiencies in the design or operation of these Portfolios, including as a result of shortcomings
or failures of processes, people or systems. Investments selected using the Portfolios may
perform differently than expected as a result of the factors used in the Portfolios, the weight
placed on each factor, changes from the factors’ historical trends, and technical issues in the
construction and implementation of the Portfolios (including, for example, data problems and/or
software issues). Moreover, the effectiveness of a Portfolio may diminish over time, including as a
result of changes in the market and/or changes in the behavior of other market participants. A
Portfolio’s return mapping is based on historical data regarding particular asset classes, which
may not be predictive of future price movements, particularly if unusual or disruptive events cause
market movements, the nature or size of which are inconsistent with the historical performance of
individual markets and their relationship to one another or to other macroeconomic events.
Operation of a Portfolio may result in negative performance, including returns that deviate
materially from historical performance, both actual and pro-forma. Additionally, commonality of
holdings across Portfolios may amplify losses. There is no guarantee that the use of the Portfolios
will result in effective investment decisions for a client’s Advisory Account.
•
Multiple Levels of Fees and Expenses—Subject to applicable law, Advisory Accounts investing
in underlying funds generally bear any asset-based fees and performance-based fees or
allocations and expenses at the Advisory Account level and at the underlying fund level
(although there may be circumstances in which Advisory Accounts bear such fees at only the
Advisory Account level).
•
Operational Risk – The risk of loss arising from shortcomings or failures in internal processes or
systems of Goldman Sachs, GS&Co., the Custodian, vendors, external events impacting those
systems, and human error. Operational risk can arise from many factors ranging from routine
processing errors to potentially costly incidents such as major system failures.
•
Passive Investing – The risk arising from passive investing. The Program assumes a preference
for passive over active investing. Passive investing may yield lower returns than active investing
during a particular time period, because passive investing is based on the theory that consistently
outperforming an efficient market is impossible, and thus passive investors do not attempt to
outperform the market at all, thereby foregoing any potential gains that could result from
outperforming the market in the short term.
•
Reliance on Data Risk – The risk arising from reliance on data. The Program relies on data from
third parties and other external sources. DAS will in its discretion determine what third-party and
external data to use in connection with the Program. The data used in the Program is obtained or
derived from sources believed to be reliable, but DAS does not verify such data and cannot
guarantee its accuracy and completeness. In addition, the Portfolio Recommendation Tool relies
on information provided by clients in recommending a Suggested Portfolio for an Advisory
Account. There is no guarantee that any specific data or type of data will be used in generating
recommendations.
•
Tax, Legal and Regulatory Risks – The risk of loss due to increased costs and reduced
investment and trading opportunities resulting from unanticipated legal, tax and regulatory
changes. Regulations, including regulations such as the Volcker rule contained within the Dodd-
Frank Act and comprehensive tax reform, may affect the types of transactions that certain clients
may enter into with Goldman Sachs and ultimately the performance of the Advisory Accounts or
the commercial benefits the client may obtain from Goldman Sachs. In addition, the California
Consumer Privacy Act (the “CCPA”) was enacted in June 2018 and is scheduled to take effect on
January 1, 2020. The CCPA will impose privacy compliance obligations with regard to the
personal information of California residents. Other states may, in the future, impose similar
privacy compliance obligations. Increased regulatory oversight may also impose additional
compliance and administrative obligations on GS&Co. and Goldman Sachs, including, without
limitation, responding to investigations and implementing new policies and procedures.
Additional information regarding such matters may also be available in the current public SEC
filings made by Goldman Sachs.
Fees The Program charges a “wrap” fee, which is currently structured as a single per-account fee that covers
investment advisory services provided by DAS and the custodial and brokerage services provided by
Custodian (“Advisory Fee”). The Advisory Fee applicable to each Advisory Account maintained by a client
is 25 basis points per year on the entire value of the Advisory Account or as otherwise specified to you in
writing by GS&Co. The Advisory Fee is determined based on the average daily value of the assets in the
applicable Advisory Account and is deducted from the Advisory Account. The Advisory Fee, in either
case, is subject to any applicable discounts, or waivers, as discussed below. The fee is paid quarterly in
arrears. The Advisory Fee is generally not negotiable, and DAS reserves the right to discount or waive
any fees associated with the Program in its sole discretion. Any fee waivers or discounts, or terminations
of such waivers or discounts, will be communicated to clients where applicable. The Advisory Fee for
certain clients, including employees of the firm or an affiliate, or clients of an affiliate, may be lower than,
but in no case shall exceed, 25 basis points per year on the entire value of the Advisory Account.
Clients should understand that the Program was designed with frequent investing in mind, and therefore
the fee structure might not be economical or appropriate for individuals intending to make few or
infrequent small-dollar investments. Clients should further understand that the Advisory Fee may exceed
the aggregate cost of purchasing separately the investment products and individual services that
comprise the advisory and brokerage services offered through the Program.
The Advisory Fee includes most of the investment expenses that are typically paid by investors, such as:
account establishment/maintenance expenses, investment advisory fees, and brokerage fees. However,
the Advisory Fee does not include fees charged by each ETF’s investment manager, or other fees and
expenses that are reflected in the price of each ETF’s shares. Expenses that are charged in addition to
the Advisory Fee and for which clients are independently responsible to the Custodian, if incurred, are
listed on Schedule A, which is attached to this Brochure. DAS reserves the right to assume the expense
of any fees set forth on Schedule A in its sole discretion.
DAS does not charge performance fees on Advisory Accounts.
Brokerage and Custody Services In order to participate in the Program, clients must enter into an agreement directly with Custodian to
serve as the custodian for client’s assets invested through the Program and provide brokerage services.
Under the terms of the Client Agreement, clients authorize and direct DAS to execute orders to buy and
sell ETFs with Custodian. DAS may combine orders for purchases or sales for multiple Advisory
Accounts.
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Disciplinary Information In the ordinary course of its business, GS&Co. and its management persons have in the past been, and
may in the future be, subject to periodic audits, examinations, claims, litigation, formal and informal
regulatory inquiries, requests for information, subpoenas, employment-related matters, disputes,
investigations, and legal or regulatory proceedings involving the SEC, other regulatory authorities, or
private parties. Such audits, investigations, and proceedings have the potential to result in findings,
conclusions, settlements, charges or various forms of sanctions against GS&Co. or its management
persons, as well as Goldman Sachs and other Goldman Sachs personnel, including fines, suspensions of
personnel, changes in policies, procedures or disclosure or other sanctions and may increase the
exposure of the Advisory Accounts, GS&Co. and Goldman Sachs to potential liabilities and to legal,
compliance and other related costs. In addition, such actions or proceedings may involve claims of strict
liability or similar risks against Advisory Accounts in certain jurisdictions or in connection with certain
types of activities.
The following legal or disciplinary events relate to GS&Co.:
The SEC brought a civil action in the U.S. District Court for the Southern District of New York against
GS&Co. and one of its employees in connection with a single collateralized debt obligation transaction
made in early 2007. On July 14, 2010, the SEC and GS&Co. entered into a consent agreement settling
this action against GS&Co. On July 20, 2010, the United States District Court entered a final judgment
approving the settlement. GS&Co. has made applications with the Financial Industry Regulatory
Authority (“FINRA”) for the continuation of certain self-regulatory organization memberships from which it
would otherwise be disqualified as a result of the final judgment.
Additional information about GS&Co.’s advisory affiliates is contained in Part 1 of GS&Co.’s Form ADV.
For information relating to other Goldman Sachs entities, please visit www.gs.com and refer to the public
filings of The Goldman Sachs Group, Inc.
Other Financial Industry Activities GS&Co. is registered with the SEC as a broker-dealer and in addition to its advisory business, is engaged
in business as a Futures Commission Merchant, commodity trading advisor, swap dealer, registered
municipal advisor and commodity pool operator. Certain of GS&Co.’s management persons may also be
registered as associated persons of GS&Co. to the extent necessary or appropriate to perform their
responsibilities.
Other Material Relationships with Affiliated Entities GS&Co. may use, suggest or recommend its own services or those of affiliated Goldman Sachs entities in
connection with its advisory business. GS&Co. may manage Accounts (as defined below) on behalf of
such affiliated Goldman Sachs entities, which may create potential conflicts of interest relating to
GS&Co.’s determination to use, suggest or recommend the services of such entities. The particular
services involved will depend on the types of services offered by the affiliate. The arrangements may
involve sharing or joint compensation, or separate compensation, subject to the requirements of
applicable law. GS&Co. may share resources or delegate certain of its trading, advisory and other
activities for clients to other businesses within GS&Co. other than DAS and/or to GS&Co.’s affiliates and
portfolio management functions may be shared or moved between affiliated advisers. Particular
relationships may include, but are not limited to, those discussed below. Goldman Sachs’ affiliates will
retain any compensation when providing investment services to, or in connection with investment
activities of, Advisory Accounts, subject to applicable law. Compensation may take the form of
commissions, markups, mark-downs, service fees or other commission equivalents. Advisory Accounts
will not be entitled to any such compensation retained by Goldman Sachs’ affiliates.
Broker-Dealer
GS&Co. is registered with the SEC as a broker-dealer. Certain of GS&Co.’s management persons may
also be registered representatives of GS&Co. to the extent necessary or appropriate to perform their
responsibilities. DAS may receive recordkeeping, administrative and support services from other parts of
GS&Co. or its affiliates. GS&Co., in its advisory capacity, obtains research ideas, analyses, reports and
other services (including distribution services) from its affiliates.
In addition, Goldman Sachs may have ownership interests in trading networks, securities or derivatives
indices, trading tools and settlement systems.
Goldman Sachs also holds ownership interests in, and Goldman Sachs personnel may sit on the boards
of directors of, national securities exchanges, electronic communication networks, alternative trading
systems and other similar execution or trading systems or venues (collectively, “Market Centers”).
Goldman Sachs may be deemed to control one or more of such Market Centers based on its levels of
ownership and its representation on the board of directors of such Market Centers. As of January 30,
2018, Goldman Sachs held ownership interests in the following Market Centers: (i) Chicago Board
Options Exchange, Inc., (ii) Chicago Stock Exchange, Inc., (iii) International Securities Exchange, LLC,
(iv) NASDAQ OMX PHLX, Inc. (formerly the Philadelphia Stock Exchange), (v) NYSE MKT LLC, (vi)
NYSE, (vii) Virtu Financial – VFCM, (viii) BIDS, (ix) Sigma X2, (x) BondDesk, (xi) Dealerweb, (xii) MTS
S.P.A, (xiii) TradeWeb and (xiv) TradeWeb Retail. Goldman Sachs may acquire ownership interests in
other Market Centers (or increase ownership in the Market Centers listed above) in the future.
Consistent with its duty to seek best execution for the Advisory Accounts, DAS may, from time to time,
indirectly through the Custodian, effect trades for Advisory Accounts through such Market Centers. In
such cases, Goldman Sachs may receive an indirect economic benefit based upon its ownership interests
in Market Centers. In addition, Goldman Sachs receives fees, cash credits, rebates, discounts or other
benefits from Market Centers to which it, as broker, routes order flow based on the aggregate trading
volume generated by Goldman Sachs (including volume not associated with client orders), the type of
order flow routed and whether the order contributes or extracts liquidity from the given market. Discounts
or rebates received by Goldman Sachs from a Market Center during any time period may or may not
exceed the fees paid by Goldman Sachs to the Market Center during that time period. The amount of
such discounts or rebates varies, but generally does not exceed $0.004 per share or $0.85 per contract
for listed options. Further, the US listed options exchanges sponsor marketing fee programs through
which registered market-makers may receive payments from the exchanges based upon their market
making status and/or as a result of their designation as a “preferenced” market maker by an exchange
member with respect to certain options orders. GS&Co. may receive payments from “preferenced”
registered market makers related to these exchange-sponsored marketing fee programs. The amount of
such payments varies, but generally does not exceed $0.70 per contract. DAS will, indirectly through the
Custodian, effect trades for an Advisory Account through such Market Centers only if DAS reasonably
believes that such trades are in the best interest of the Advisory Account and that the requirements of
applicable law have been satisfied.
Through GS&Co.’s trading on or membership to various trading platforms or venues or interactions with
certain service providers (including depositaries and messaging platforms), GS&Co. and its affiliates may
receive interests, shares or other economic benefits from such service providers.
Investment Companies and Other Pooled Investment Vehicles
GS&Co. has affiliates, including Goldman Sachs Asset Management, L.P. (“GSAM”), that act in an
advisory or sub-advisory capacity and other capacities, including as trustee, managing member, adviser,
administrator and/or distributor to a variety of U.S. and non-U.S. investment companies as well as other
pooled investment vehicles including collective trusts, ETFs, closed end funds, business development
companies, private investment funds, special purpose acquisition vehicles and operating companies.
Certain personnel of GS&Co. are also directors, trustees and/or officers of these investment companies
and other pooled investment vehicles. Affiliates of GS&Co. that act as investment adviser or manager of
an investment company or pooled vehicle, including ETFs (collectively, “Funds”), will receive
management or advisory fees in connection with their advisory roles. Although such fees are generally
paid by the Funds, the costs are ultimately borne by shareholders.
Other Investment Advisers
GS&Co. has investment advisory affiliates in and outside of the United States that are registered with the
SEC as investment advisers. These affiliates include, but are not limited to The Ayco Company, L.P.
(“Ayco”), GSAM, Goldman Sachs Asset Management International (“GSAMI”), Goldman Sachs Hedge
Fund Strategies LLC (“HFS”), GS Investment Strategies, LLC (“GSIS”), and United Capital Financial
Advisers, LLC (“United Capital”).
Clients may be offered access to advisory services through GS&Co., GSAM, GSAMI, or other affiliated
investment advisers. These investment advisers manage accounts according to different strategies and
may also apply different criteria to the same or similar products. Since GSAM’s, GSAMI’s, and GS&Co.’s
investment decisions are made independently, GSAM and/or GSAMI may be buying while GS&Co. is
selling, or vice versa. Therefore, it is possible that an account managed by GS&Co., GSAM or GSAMI
could sustain losses during periods in which GS&Co. and its affiliates, and other GS&Co., GSAM, or
GSAMI-managed managed accounts, achieve significant profits on their trading.
GS&Co. may, in its discretion, delegate all or a portion of its advisory or other functions (including placing
trades on behalf of Advisory Accounts) to any affiliate that is registered with the SEC as an investment
adviser or to any of its non-US affiliated advisers. GS&Co. may also move or share portfolio
management between affiliated advisers. This might include the movement of portfolio managers from
GS&Co. to an affiliated adviser or the transfer of management of the portfolio to a management team
within an affiliated adviser. Clients will be notified of any such movements or transfers of portfolio
management in advance.
A copy of the brochure of GSAM, GSAMI, or other affiliated investment advisers is available on the SEC’s
website (www.adviserinfo.sec.gov) and will be provided to clients or prospective clients upon request.
Clients that want more information about any of these affiliates should contact GS&Co.
Financial Planner
GS&Co.’s affiliate, Ayco, provides financial counseling and planning services, investment management,
financial education and other services to publicly traded companies and privately held firms (“Ayco
Corporate Clients”) and their respective executives and employees and high net worth individuals. Ayco
receives fees from Ayco Corporate Clients for providing such services, and its personnel will receive fees
from GS&Co. for recommending investment advisory services to Ayco’s clients. Ayco will make DAS
available to executives and employees of Ayco Corporate Clients, subject to such Client’s approval.
Banking or Thrift Institution
Banks
The Goldman Sachs Group, Inc. is a bank holding company under the BHCA. As a bank holding
company, The Goldman Sachs Group, Inc. is subject to supervision and regulation by the Federal
Reserve Board.
Goldman Sachs Bank USA (“GS Bank”) is a Federal Deposit Insurance Corporation (“FDIC”) insured New
York State-chartered Federal Reserve member bank. GS Bank accepts brokered and omnibus deposits,
lends to individuals and corporate clients, transacts in certain derivatives, and provides securities lending,
custody and hedge fund administration services. DAS clients may open separate savings accounts and
certificates of deposit, as well as enter into lending transactions, with GS Bank.
Trust Companies
The Goldman Sachs Trust Company, N.A., a national bank limited to fiduciary activities (“GSTC”), and
The Goldman Sachs Trust Company of Delaware, a Delaware limited purpose trust company (“GSTD”),
may provide personal trust and estate administration and related services to GS&Co.’s clients. Goldman
Sachs may provide a variety of services to GSTC and GSTD, including investment advisory, distribution,
marketing, operational, infrastructure, financial, auditing and administrative services. Goldman Sachs will
receive fees from GSTC and GSTD according to the fee schedules agreed upon between the parties in
arm’s-length service agreements.
Insurance Company or Agency
The Ayco Services Agency, L.P. and the Ayco Services Insurance Agency, Inc. can sell insurance
contracts, including, but not limited to, variable life and variable annuity insurance contracts. GS&Co. may
refer clients to these related affiliates and will receive referral fees subject to applicable law.
Sponsor or Syndicator of Limited Partnerships
Goldman Sachs creates and/or distributes unregistered privately placed vehicles in which clients may
invest and for which it receives fees.
Management Persons; Policies and Procedures
Certain of GS&Co.’s management persons may also hold positions with one or more of the Goldman
Sachs affiliates listed above. In any such positions, they may have some responsibility with respect to the
business of these affiliates and receive compensation based, in part, upon the profitability of these
affiliates. Consequently, in carrying out their roles at GS&Co. and these affiliates, the management
persons of GS&Co. will be subject to the same or similar potential conflicts of interest that exist between
GS&Co. and these affiliates.
GS&Co. has established a variety of restrictions, policies, procedures, and disclosures designed to
address potential conflicts that arise between GS&Co., its management persons and its affiliates. These
policies and procedures include information barriers designed to prevent the flow of information between
GS&Co., its personnel, and certain other affiliates. No assurance can be made that any of GS&Co.’s
current policies and procedures, or any policies and procedures that are established by GS&Co. in the
future will have their desired effect.
Additional information about these conflicts and the policies and procedures designed to address them is
available in “Code of Ethics and Personal Trading,” “Trade Handling,” and “Participation or Interest in
Client Transactions” for more information.
Code of Ethics and Personal Trading GS&Co. has adopted a Code of Ethics (the “Code”) under Rule 204A-1 of the Investment Advisers Act of
1940, as amended (the “Investment Advisers Act”), designed to provide that personnel involved in
investment decision-making for clients comply with applicable federal securities laws and place the
interests of clients first in conducting personal securities transactions. The Code imposes certain
restrictions on securities transactions in the personal accounts of covered persons to help avoid conflicts
of interest. Subject to the limitations of the Code, covered persons may buy and sell securities or other
investments for their personal accounts, including investments in pooled investment vehicles that are
sponsored, managed, or advised by Goldman Sachs, and may also take positions that are the same as,
different from, or made at different times than, positions taken for Advisory Accounts. GS&Co. provides a
copy of the Code to clients or prospective clients upon request.
Employees are also subject to firm-wide policies and procedures regarding confidential and proprietary
information, information barriers, private investments, outside business activities, and personal trading.
In addition, GS&Co. prohibits its employees from accepting gifts and entertainment that could influence,
or appear to influence, their business judgment. This generally includes gifts of more than $100 or
meals and other business-related entertainment that may be considered lavish or extraordinary and
therefore raise a question or appearance of impropriety.
Nonetheless, because the Code in some circumstances would permit employees to invest in the same
securities as clients, there is a possibility that employees might benefit from market activity by a client.
Employee trading is monitored under the Code to reasonably prevent conflicts of interest between
GS&Co. and its clients. Clients may request a copy of GS&Co.’s Code by calling us at 1-833-474-6837 if
they utilize the GS Site or by calling us at 1-855-783-7283 if they utilize the HD Site.
Trade Handling Employee Accounts
Employees or related persons of GS&Co. may open Advisory Accounts in the Program, and as a result
trade in the same securities with unaffiliated clients. DAS’s procedure is to treat any employee’s Advisory
Account or related person’s Advisory Account in the same fashion as unaffiliated clients’ Advisory
Accounts.
Client Accounts
Trades may be done on an aggregated basis when consistent with GS&Co.’s obligation to seek best
execution. In such circumstances, GS&Co. (or a related account) and Advisory Accounts receive
securities at a total average price. GS&Co. retains records of the trade order (specifying each
participating account) and its allocation, which are completed prior to the entry of the aggregated order.
Completed orders are allocated as specified in the initial trade order. Partially filled orders are allocated
on a pro rata basis. Any exceptions will be explained on the order.
From time to time, DAS’s unaffiliated Custodian, Apex Clearing Corporation, receives compensation in
the form of rebates, monetary compensation, or inter-company transfer of funds for routing customer
orders, including orders for DAS’s clients, to a designated exchange, market maker, dealer, or market
center for execution. GS&Co. does not receive any payments from Apex in connection with such order
flow, and in all cases seeks the best execution possible for its clients’ orders.
In order to permit sufficient time to ensure that the transfer of assets into a client’s Advisory Account has
been successfully completed by the financial institution that maintains such client’s bank account, DAS
will generally wait at least one Business Day after the day the Custodian credits the applicable deposit to
such client’s Advisory Account to generate and place trade orders for such purchases. “Business Day”
means a day when the New York Stock Exchange is open for trading and banking institutions located in
the State of New York are open for business during all or part of the day. As a result, each deposit or
transfer a client makes will generally not be invested in such client’s Selected Portfolio for at least one
Business Day after the day the Custodian credits the applicable deposit, and such uninvested cash will
not be subject to financial gains or losses resulting from movement in market prices during that time
period.
DAS reserves the right, at any time and without notice, to delay or manage the trading of client orders if
DAS determines it is appropriate and consistent with its obligations under the Client Agreement.
Participation or Interest in Client Transactions GS&Co. acts as investment adviser under the Investment Advisers Act in accordance with fiduciary
standards. Goldman Sachs is a worldwide, full-service investment banking, broker-dealer, asset
management and financial services organization and a major participant in global financial markets. As
such, Goldman Sachs provides a wide range of financial services to a substantial and diversified client
base that includes corporations, financial institutions, governments, and individuals. Goldman Sachs acts
as an investment banker, research provider, investment manager, financier, advisor, market maker, prime
broker, derivatives dealer, lender, counterparty, agent, and principal. In those and other capacities,
Goldman Sachs advises clients in all markets and transactions, and purchases, sells, holds, and
recommends a broad array of investments, securities, derivatives, loans, commodities, currencies, credit
default swaps, indices, baskets, and other financial instruments and products for its own accounts and for
the accounts of clients and of its personnel, through client accounts and the relationships and products it
sponsors, manages, and advises (such Goldman Sachs or other client accounts, relationships, and
products collectively, the “Accounts”). Goldman Sachs has direct and indirect interests in the global fixed
income, currency, commodity, equities, bank loan, and other markets, and may have an interest in the
securities and issuers in which Advisory Accounts directly and indirectly invest. As a result, Goldman
Sachs’ activities and dealings will affect Advisory Accounts in ways that may disadvantage or restrict
Advisory Accounts and/or benefit Goldman Sachs or other Accounts (including Advisory Accounts). The
following are descriptions of certain conflicts of interest and potential conflicts of interest that may be
associated with the financial or other interests that Goldman Sachs may have in transactions effected by,
with, and on behalf of, Advisory Accounts.
Certain Effects of Goldman Sachs Activities on Advisory Accounts
Goldman Sachs engages in a variety of activities in the global financial markets. The extent of Goldman
Sachs’ activities in the global financial markets, including, without limitation, in its capacity as an
investment banker, research provider, investment adviser, financier, adviser, market maker, prime broker,
derivatives dealer, lender, counterparty, agent, principal and investor, as well as in other capacities, may
have potential adverse effects on Advisory Accounts. Goldman Sachs provides advisory services to
Accounts through a variety of investment products and arrangements. DAS’s decisions and actions on
behalf of an Advisory Account may differ from those on behalf of other Advisory Accounts. Advice given
to, or investment or voting decisions made for, one or more Accounts may compete with, affect, differ
from, conflict with, or involve timing different from, advice given to or investment or voting decisions made
for other Accounts, including, where applicable, Advisory Accounts of Program clients. Goldman Sachs
(including DAS), the clients it advises, and its personnel may have interests in and advise Accounts,
including Advisory Accounts, that have investment objectives or portfolios similar to, related to or opposed
to those of particular Advisory Accounts. Goldman Sachs may receive greater fees or other
compensation from such Accounts than it does from the particular Advisory Accounts. In addition,
Goldman Sachs (including GS&Co.), the clients it advises, and its personnel may engage (or consider
engaging) in commercial arrangements or transactions with Accounts, and/or may compete for
commercial arrangements or transactions in the same types of companies, assets, securities and other
instruments, as particular Advisory Accounts. Within the Program, decisions and actions of GS&Co. on
behalf of a particular Advisory Account may differ from those on behalf of other Advisory Accounts.
Advice given to, or investment decisions made for, one or more Advisory Accounts may compete with,
affect, differ from, conflict with, or involve timing different from, advice given to or investment decisions
made for other Advisory Accounts. Transactions by, advice to and activities of Goldman Sachs clients
(including with respect to investment decisions, voting and the enforcement of rights) may involve the
same or related companies, securities, or other instruments as those in which particular Advisory
Accounts invest, and such clients may engage in a strategy while an Advisory Account is undertaking the
same or a differing strategy, any of which could directly or indirectly disadvantage the Advisory Account
(including its ability to engage in a transaction or other activities) or the prices or terms at which the
Advisory Account’s transactions or other activities may be effected. For example, Goldman Sachs may
be engaged to provide advice to a client that is considering entering into a transaction with a particular
Account, and Goldman Sachs may advise the client not to pursue the transaction with the particular
Account, or otherwise in connection with a potential transaction provide advice to the client that would be
adverse to the particular Account. Additionally, an Advisory Account may buy a long security and
Goldman Sachs or a Goldman Sachs client may establish a short position in that same security or in
similar securities. If created, the short position may result in the impairment of the price of the security
that an Advisory Account holds or could be designed to profit from a decline in the price of the security.
To the extent an Advisory Account engages in transactions in the same or similar types of securities as
other Goldman Sachs clients (including through other Advisory Accounts), such Advisory Accounts and
other clients may compete for such transactions or investments, and transactions or investments by such
other clients may negatively affect the investments of the Advisory Account (including the ability of the
Advisory Account to engage in such a transaction or investment or other activities), or the price or terms
at which the Advisory Account’s transactions, investments, or other activities may be effected. Moreover,
a particular Advisory Account on the one hand, and Goldman Sachs or a Goldman Sachs client (including
through another Advisory Account) on the other hand, may vote differently on, or take or refrain from
taking different actions with respect to, the same security, which can be disadvantageous to the Advisory
Account.
GS&Co. may cause Advisory Accounts to invest, directly or indirectly, in securities or other obligations of
companies affiliated with Goldman Sachs, advised by Goldman Sachs (including GS&Co.) or in which
Goldman Sachs or Accounts (including Advisory Accounts) have an equity, debt, or other interest, or to
engage in investment transactions that may result in Goldman Sachs or Goldman Sachs clients (including
through other Advisory Accounts) being relieved of obligations or otherwise divested of investments. For
example, an Advisory Account may acquire securities or indebtedness of a company affiliated with
Goldman Sachs directly or indirectly through syndicate or secondary market purchases, or may make a
loan to, or purchase securities from, a company that uses the proceeds to repay loans made by Goldman
Sachs. These activities by an Advisory Account may enhance the profitability of Goldman Sachs or
Goldman Sachs clients (including Advisory Accounts) with respect to their investment in, and activities
relating to, such companies. Advisory Accounts will not be entitled to compensation as a result of this
enhanced profitability.
Goldman Sachs may make loans to, or enter into margin, asset-based or other credit facilities or similar
transactions with, clients, companies, or individuals, that may (or may not) be secured by publicly or
privately held securities or other assets. Some of these borrowers may be public or private companies, or
founders, officers or shareholders in companies in which Goldman Sachs, funds managed by Goldman
Sachs, or Advisory Accounts or other accounts may (directly or indirectly) invest, and such loans may be
secured by securities of such companies, which may be the same as, or pari passu with or more senior or
junior to, interests held (directly or indirectly) by Goldman Sachs, funds managed by Goldman Sachs,
Advisory Accounts or other Accounts. In connection with its rights as lender, Goldman Sachs may act to
protect its own commercial interest and may take actions that adversely affect the borrower, including by
liquidating or causing the liquidation of securities on behalf of a borrower or foreclosing and liquidating
such securities in Goldman Sachs’ own name. Such actions may adversely affect Advisory Accounts
(e.g., if a large position in securities is liquidated, among the other potential adverse consequences, the
value of such security may decline rapidly and Advisory Accounts holding (directly or indirectly) such
security may in turn decline in value or may be unable to liquidate their positions in such security at an
advantageous price or at all).
Goldman Sachs may create, write, sell, issue, invest in or act as placement agent or distributor of
derivative instruments related to securities issued by Goldman Sachs or its affiliates, including structured
investments, and separately managed accounts and pooled vehicles managed by Goldman Sachs
(“Affiliated Product”), or with respect to underlying securities or assets of Affiliated Products, or which may
be otherwise based on, or seek to replicate or hedge, the performance of Affiliated Products. Such
derivative transactions, and any associated hedging activity, may differ from, and be adverse to, the
interests of Advisory Accounts. For example, derivative transactions could represent leveraged
investments in an investment fund in which Advisory Accounts have an interest, and the leveraged
characteristics of such investments could make it more likely, due to events of default or otherwise, that
there would be significant redemptions of interests from such underlying fund more quickly than might
otherwise be the case. Goldman Sachs, acting in commercial capacities in connection with such
derivative transactions, may in fact cause such a redemption. Activities in respect of derivative
transactions, and any associated hedging activity, may occur as a result of Goldman Sachs’ adjustment in
assessment of an investment or a manager, whether they are affiliated or unaffiliated with Goldman
Sachs, based on various considerations, and Goldman Sachs will not be under any obligation to provide
notice to Advisory Accounts in respect of any such adjustment in assessment.
Goldman Sachs and its personnel, when acting as an investment banker, research provider, investment
adviser, financier, adviser, market maker, prime broker, derivatives dealer, lender, counterparty, or
investor, or in other capacities, may advise on transactions, make investment decisions or
recommendations, provide differing investment views or have views with respect to research or valuations
that are inconsistent with, or adverse to, the interests and activities of Accounts. Clients may be offered
or otherwise have access to advisory services through several different Goldman Sachs advisory
businesses (including through Ayco, GS&Co.’s Private Wealth Management group, and GSAM).
Different advisory businesses within Goldman Sachs manage Accounts according to different strategies
and may also apply different criteria to the same or similar strategies and may have differing or opposite
investment views in respect of an issuer or a security or other investment. Similarly, Goldman Sachs
personnel can have differing or opposite investment views in respect of an issuer or a security, and the
positions DAS takes in respect of an Advisory Account may be inconsistent with, or adverse to, the
interests and activities of Accounts advised by other Goldman Sachs personnel. Moreover, research,
analyses, or viewpoints will be available to clients or potential clients at different times. Goldman Sachs
will not have any obligation to make available to the Advisory Accounts any research or analysis prior to
its public dissemination. Goldman Sachs, on behalf of itself or its clients (including Advisory Accounts),
may implement an investment decision or strategy ahead of, or contemporaneously with, or behind
similar investment decisions or strategies made for particular Advisory Accounts (whether or not the
investment decisions emanate from the same research analysis or other information). The relative timing
for the implementation of investment decisions or strategies among Advisory Accounts, on the one hand,
and other clients (including Accounts), on the other hand, may disadvantage the Advisory Accounts.
Certain factors, for example, market impact, liquidity constraints, or other circumstances, could result in
Advisory Accounts in the Program receiving less favorable investment or trading results or incurring
increased costs associated with implementing such investment decisions or strategies, or being
otherwise disadvantaged, as compared to the Accounts of other clients of other Goldman Sachs
advisers.
Additionally, DAS faces conflicts of interest arising out of Goldman Sachs’ relationships and business
dealings in connection with decisions to take or refrain from taking certain actions on behalf of Advisory
Accounts when doing so would be adverse Goldman Sachs’ relationships or other business with such
parties.
DAS uses the Portfolios to manage the Advisory Accounts. Prior to DAS’s investment advisory personnel
having had the chance to evaluate or act upon the recommendations in any of the Portfolios, other
Accounts, including those advised by GS&Co. and its affiliates, may have already begun to trade based
upon the recommendations in the Portfolios. As a result, trades ultimately placed on behalf of Advisory
Accounts, based upon the Portfolios, may be subject to price movements, particularly with large orders or
thinly traded securities. This may result in the Advisory Accounts receiving prices for transactions that are
less favorable than the prices for transactions obtained for other clients of Goldman Sachs. This could
occur because of time zone differences or other reasons that cause orders to be placed at different times.
In addition, the Portfolios available through DAS might not be available through affiliates of GS&Co., and
vice versa, and might experience different performance than other model portfolios.
Considerations Relating to Information Held by Goldman Sachs
Goldman Sachs has established certain information barriers and other policies to address the sharing of
information between different businesses within Goldman Sachs and within GS&Co. As a result of
information barriers, DAS generally does not have access, or has limited access, to information and
personnel in other areas of Goldman Sachs relating to business transactions for clients (including
transactions in investing, banking, prime brokerage and certain other areas), and generally will not
manage the Advisory Accounts with the benefit of information held by these other areas. Goldman
Sachs, due to its access to, and knowledge of, funds, markets, and securities based on its prime
brokerage and other businesses, may make decisions based on information or take (or refrain from
taking) actions with respect to interests in investments of the kind held by Advisory Accounts in a manner
that will be adverse to Advisory Accounts and Goldman Sachs will not have any obligation to share
information with DAS. In addition, regardless of the existence of information barriers, Goldman Sachs will
not have any obligation to make available any information regarding its trading activities, strategies, or
views, or the activities, strategies, or views used for other Accounts for the benefit of Advisory Accounts.
Different areas of GS&Co. and Goldman Sachs may take views, and make decisions or
recommendations, that are different than other areas of GS&Co., including DAS, and Goldman Sachs.
To the extent that DAS personnel have access to fundamental analysis and proprietary technical models
or other information developed by Goldman Sachs and its personnel, DAS personnel will not be under
any obligation to effect transactions on behalf of the Advisory Accounts in accordance with such analysis
and models, except as otherwise required under the Client Agreement. Different personnel within DAS
may make decisions based on information or take (or refrain from taking) actions with respect to Advisory
Accounts they advise in a manner that may be different than or adverse to other Advisory Accounts.
Such teams may not share information with other portfolio management teams within GS&Co. (or other
areas of Goldman Sachs), including as a result of certain information barriers and other policies, and will
not have any obligation to do so.
Goldman Sachs operates a business known as Goldman Sachs Securities Services (“GSS”), which
provides prime brokerage, administrative and other services to clients that may involve investment funds
in which Advisory Accounts have an interest or markets and securities in which Advisory Accounts invest.
GSS and other parts of Goldman Sachs have broad access to information regarding the current status of
certain markets, investments and funds and detailed information about fund operators that is not available
to DAS. In addition, Goldman Sachs may act as a prime broker to one or more investment funds in which
Advisory Accounts have an interest, in which case Goldman Sachs will have information concerning the
investments and transactions of such investment fund that is not available to DAS. As a result of these
and other activities, parts of Goldman Sachs may be in possession of information in respect of markets,
investments, and investment funds, which, if known to DAS, might cause DAS to seek to dispose of,
retain, or increase interests in investments held by Advisory Accounts or acquire certain positions on
behalf of Advisory Accounts, or take other actions. Goldman Sachs will be under no obligation or fiduciary
or other duty to make any such information available to DAS or personnel involved in decision-making for
Advisory Accounts.
Goldman Sachs May Act in Multiple Commercial Capacities
Goldman Sachs provides various services to Accounts or to companies or affiliated or unaffiliated
investment funds, or their personnel, in which Advisory Accounts have an interest, which results in fees,
compensation, and remuneration, as well as other benefits to Goldman Sachs. Such fees,
compensation, and remuneration may be substantial. In addition, Goldman Sachs may act as broker,
dealer, agent, lender or adviser or in other commercial capacities for Accounts or companies or affiliated
or unaffiliated investment funds in which Advisory Accounts have an interest. An example of this is that a
company in which an Advisory Account has an interest may hire Goldman Sachs to provide
underwriting, merger advisory, placement agency, foreign currency hedging, research, asset
management services, brokerage services, or other services to the company. Goldman Sachs may also
provide investment advice to personnel of investment advisers unaffiliated with Goldman Sachs
(“Unaffiliated Advisers”) that manages an underlying fund in which an Advisory Account invests. In
connection with providing such services, Goldman Sachs may take commercial steps in its own
interests, may advise the parties to which it is providing services to take actions or engage in
transactions, or take other actions which may have an adverse effect on Advisory Accounts. For
example, Goldman Sachs, through its banking division, may advise a company to make changes to its
capital structure the results of which would be a reduction in the value or priority of a security held by
one or more Advisory Accounts. Actions taken or advised to be taken by Goldman Sachs in connection
with other types of transactions may also result in adverse consequences for Advisory Accounts.
Providing such services to the Advisory Accounts and companies and affiliated or unaffiliated investment
funds (or their applicable personnel) in which they invest may enhance Goldman Sachs’ relationships
with various parties, facilitate additional business development and enable Goldman Sachs to obtain
additional business and generate additional revenue. Advisory Accounts will not be entitled to
compensation related to any such benefit to businesses of Goldman Sachs or DAS.
Goldman Sachs’ activities on behalf of its clients may also restrict investment opportunities that may be
available to Advisory Accounts. For example, Goldman Sachs is often engaged by companies as a
financial advisor, or to provide financing or other services, in connection with commercial transactions that
may be potential investment opportunities for Advisory Accounts.
There may be circumstances in which Advisory Accounts are precluded from participating in such
transactions as a result of Goldman Sachs’ engagement by such companies. Goldman Sachs reserves
the right to act for these companies in such circumstances, notwithstanding the potential adverse effect
on Advisory Accounts. Goldman Sachs (including GS&Co.) may also represent creditor or debtor
companies in proceedings under Chapter 11 of the U.S. Bankruptcy Code (and equivalent non-U.S.
bankruptcy laws) or prior to these filings. From time to time, Goldman Sachs (including GS&Co.) may
serve on creditor or equity committees. These actions, for which Goldman Sachs (or GS&Co., as
applicable) may be compensated, may limit or preclude the flexibility that the Advisory Account may
otherwise have to buy or sell securities issued by those companies.
In addition, GS&Co. may gather information in the course of such other activities and relationships about
companies in which a client holds or may in the future hold an interest. In the event that Goldman Sachs
is consulted in connection with opportunities with respect to these companies, GS&Co. shall have no
obligation to disclose such information, any other non-public information which is otherwise subject to an
obligation of confidence to another person, or the fact that GS&Co. is in possession of such information,
to the client or to use such information on the client’s behalf. As a result of actual or potential conflicts,
GS&Co. may not be able to provide a client with information or certain services with respect to a particular
opportunity.
Goldman Sachs-Sourced Investment Opportunities
Goldman Sachs businesses outside of DAS are under no obligation to provide investment opportunities
to Advisory Accounts, and generally are not expected to do so. Opportunities not allocated to Advisory
Accounts may be undertaken by Goldman Sachs, including for Goldman Sachs’ accounts, or made
available to other Accounts or third parties.
Goldman Sachs Policies and Regulatory Restrictions Affecting Advisory Accounts
GS&Co. may restrict its investment decisions and activities on behalf of an Advisory Account in various
circumstances, including as a result of applicable regulatory requirements, information held by Goldman
Sachs, Goldman Sachs’ roles in connection with other clients and in the capital markets (including in
connection with advice it may give to such clients or commercial arrangements or transactions that may
be undertaken by such clients or by Goldman Sachs), Goldman Sachs’ internal policies and/or potential
reputational risk in connection with Accounts (including Advisory Accounts). As a result, GS&Co. might
not engage in transactions for, or recommend transactions to, an Advisory Account, or may reduce an
Advisory Account’s position in an investment with limited availability to create availability for an Advisory
Account managed in the same strategy, in consideration of Goldman Sachs’ activities outside an Advisory
Account. For example, GS&Co. may restrict or limit the amount of an Advisory Account’s investment
where exceeding a certain aggregate amount could require a filing or a license or other regulatory or
corporate consent, which could, among other things, result in additional costs and disclosure obligations
for or impose regulatory restrictions on Goldman Sachs, including GS&Co or on other Advisory Accounts,
or where exceeding a threshold is prohibited or may result in regulatory or other restrictions. In certain
cases, restrictions and limitations will be applied to avoid approaching such thresholds. Circumstances in
which such restrictions or limitations may arise include, without limitation: (i) a prohibition against owning
more than a certain percentage of an issuer’s securities; (ii) a “poison pill” that could have a dilutive
impact on the holdings of the Advisory Accounts should a threshold be exceeded; (iii) provisions that
would cause Goldman Sachs to be considered an “interested stockholder” of an issuer; (iv) provisions
that may cause Goldman Sachs to be considered an “affiliate” or “control person” of the issuer; and (v)
the imposition by an issuer (through charter amendment, contract or otherwise) or governmental,
regulatory or self-regulatory organization (through law, rule, regulation, interpretation or other guidance)
of other restrictions or limitations. When faced with the foregoing limitations, Goldman Sachs will
generally avoid exceeding the threshold because it could have an adverse impact on the ability of
Goldman Sachs to conduct business activities.
GS&Co. may also reduce a particular Advisory Account’s interest in, or restrict certain Advisory Accounts
from participating in, an investment opportunity that has limited availability so that other Advisory
Accounts that pursue similar investment strategies may be able to acquire an interest in the investment
opportunity. GS&Co. may determine not to engage in certain transactions or activities which may be
beneficial to Advisory Accounts because engaging in such transactions or activities in compliance with
applicable law would result in significant cost to, or administrative burden on, Goldman Sachs (including
GS&Co.) or create the potential risk of trade or other errors. In addition, GS&Co. generally is not
permitted to obtain or use material nonpublic information in effecting purchases and sales in public
securities transactions for Advisory Accounts. Restrictions (such as limits on purchase and sale
transactions) may be imposed on particular Advisory Accounts and not on other Accounts (including other
Advisory Accounts). For example, directors, officers and employees of Goldman Sachs may take seats
on the boards of directors of, or have board of directors observer rights with respect to, companies in
which GS&Co. invests on behalf of Advisory Accounts. To the extent a director, officer or employee of
Goldman Sachs were to take a seat on the board of directors of, or have board of directors observer
rights with respect to, a public company, GS&Co. may be limited and/or restricted in its or their ability to
trade in the securities of the company. In addition, any such director, officer or employee of Goldman
Sachs that is a member of the board of directors of a company in which Goldman Sachs invests on
behalf of Advisory Accounts may have duties to such company in his or her capacity as a director that
conflict with Goldman Sachs’s duties to Advisory Accounts, and may act in a manner that may
disadvantage or otherwise harm Advisory Accounts and/or benefit the portfolio company and/or Goldman
Sachs.
Different areas of Goldman Sachs may come into possession of material non-public information regarding
an issuer of securities held by an investment fund in which an Advisory Account invests. In the absence
of information barriers between such different areas of Goldman Sachs, the Advisory Account may be
prohibited, including by internal policies, from redeeming from such investment fund during the period
such material non-public information is held by such other part of Goldman Sachs, which period may be
substantial. As a result, the Advisory Account may not be permitted to redeem from an investment fund in
whole or in part during periods when it otherwise would have been able to do so, which could adversely
affect the Advisory Account. Other investors in the investment fund that are not subject to such
restrictions may be able to redeem from the investment fund during such periods.
Goldman Sachs operates a program reasonably designed to ensure compliance generally with economic
and trade sanctions-related obligations applicable directly to its activities (although such obligations are
not necessarily the same obligations that an Advisory Account may be subject to). Such economic and
trade sanctions may prohibit, among other things, transactions with and the provision of services to,
directly or indirectly, certain countries, territories, entities and individuals. These economic and trade
sanctions, and the application by Goldman Sachs of its compliance program in respect thereof, may
restrict or limit an Advisory Account’s investment activities.
GS&Co. may determine to limit or not engage at all in an activity or transaction engaged in on behalf of a
particular Advisory Account, and may limit its exercise of rights on behalf of the Advisory Account for
reputational or other reasons, including: (i) where Goldman Sachs is providing (or may provide) advice or
services to an entity involved in such activity or transaction; (ii) where Goldman Sachs or an Account is or
may be engaged in the same or a related transaction to that being considered on behalf of the Advisory
Account; or (iii) where Goldman Sachs or another Account has an interest in an entity involved in such
activity or transaction that could affect Goldman Sachs, GS&Co., or their activities. GS&Co. may restrict
its investment decisions and activities on behalf of particular Advisory Accounts and not other Accounts
(including other Advisory Accounts).
In order to engage in certain transactions on behalf of Advisory Accounts, GS&Co. will also be subject to
(or cause Advisory Accounts to become subject to) the rules, terms and/or conditions of any venues
through which it trades securities, derivatives or other instruments. This includes, but is not limited to,
where GS&Co. and/or the Advisory Accounts may be required to comply with the rules of certain
exchanges, execution platforms, trading facilities, clearinghouses and other venues, or may be required
to consent to the jurisdiction of any such venues. The rules, terms and/or conditions of any such venue
may result in GS&Co. and/or the Advisory Accounts being subject to, among other things, margin
requirements, additional fees and other charges, disciplinary procedures, reporting and recordkeeping,
position limits and other restrictions on trading, settlement risks and other related conditions on trading
set out by such venues. From time to time, an Advisory Account, GS&Co. or its affiliates and/or their
service providers or agents may be required, or may determine that it is advisable, to disclose certain
information about an Advisory Account, including, but not limited to, investments held by the Advisory
Account, and the names and percentage interest of beneficial owners thereof, to third parties, including
advisers, local governmental authorities, regulatory organizations, taxing authorities, markets, exchanges,
clearing facilities, custodians, brokers and trading counterparties of, or service providers to, GS&Co.,
advisers or underlying funds or the Advisory Account. GS&Co. will comply with requests to disclose such
information as it so determines, including through electronic delivery platforms. If GS&Co. is not permitted
to make certain required disclosures in respect of an Advisory Account, GS&Co. may determine to cause
the sale of certain assets for the Advisory Account, and such sale may be at a time that is inopportune
from a pricing or other standpoint. In addition, Goldman Sachs may provide third parties with aggregated
data regarding the activities of, or certain performance or other metrics associated with, the Advisory
Accounts it manages, and Goldman Sachs may receive compensation from such third parties for
providing them such information.
GS&Co. may determine to limit or not engage at all in transactions and activities on behalf of Advisory
Accounts, for reputational or other reasons. Examples of when such determinations may be made
include, but are not limited to, where Goldman Sachs is providing (or may provide) advice or services to
an entity involved in such activity or transaction, where Goldman Sachs or an Account is or may be
engaged in the same or a related activity or transaction to that being considered on behalf of the Advisory
Account, where Goldman Sachs or another Account has an interest in an entity involved in such activity
or transaction, where there are political, public relations, or other reputational considerations relating to
counterparties or other participants in such activity or transaction or where such activity or transaction on
behalf of or in respect of the Advisory Account could affect in tangible or intangible ways Goldman Sachs,
an Account or their activities.
Conflicts of Interest Associated with Unaffiliated Advisers
Unaffiliated Advisers, including investment managers of ETFs available in the Program, have interests
and relationships that may create conflicts of interest related to their management of the ETFs to which
Advisory Account assets are allocated. For information about conflicts of interest that may arise in
connection with the activities of Unaffiliated Advisers of the ETFs available in the Program, please refer
to the prospectuses, offering memoranda and constituent documents of such ETFs and to the Forms
ADV of such Unaffiliated Advisers.
Review of Accounts DAS’s trade operations personnel periodically review Advisory Accounts to determine whether Advisory
Account holdings significantly deviate from the Selected Portfolios. Clients are provided with periodic
reports through the Site that include information relating to ETF holdings and account balances.
Clients should understand that DAS relies on the information they provide through the Site to provide
advisory services under the Program. Clients should notify DAS immediately in the event of material
changes to their financial circumstances or any other information that might affect the recommendation of
a Suggested Portfolio. DAS will, at least annually, contact clients via e-mail or other electronic means to
determine whether there have been any changes to their account profile information and whether the
client would like to impose or change any reasonable restrictions. DAS will also, at least quarterly, notify
clients that they should contact DAS if there have been any changes to their account profile information or
if they would like to impose or change any reasonable restrictions on their account. In addition, clients
may update their account profile information at any time through, or as directed through, the Site.
Client Referrals and Other Compensation From time to time, GS&Co. may make cash payments for client referrals to third parties consistent with
applicable laws, including Rule 206(4)-3 under the Advisers Act of 1940. The compensation
arrangements generally are either a flat fee calculated and paid on a periodic basis or a fee based on a
percentage of the Advisory Fees paid to GS&Co. by the referred clients and are disclosed to clients. In
addition, from time to time, GS&Co. may compensate employees of GS&Co. and its affiliates for client
referrals pursuant to applicable laws. Separately, GS&Co. has relationships with one or more
advertisers, including operators of websites matching consumers with providers of various financial
products and services, pursuant to which GS&Co. compensates such advertiser for the advertising
services provided. GS&Co. may also purchase coupons from third parties and distribute such coupons to
potential clients. Such advertising relationships and promotions are not subject to the conflicts associated
with Rule 206(4)-3 because the advertisers’ and other third parties’ compensation is not related to any
client referrals.
Voting Client Securities DAS does not accept authority to vote client securities held in Advisory Accounts. It is DAS’s policy that
clients must vote securities held in their Advisory Account directly, appoint or instruct the Custodian
holding such securities as nominee to do so, or appoint an unaffiliated provider of proxy voting services
to vote proxies in connection with certain securities on the client’s behalf. Clients are responsible for
voting proxies on securities or matters on which their proxy voting service provider or the Custodian
declines to vote. DAS does not render any advice with respect to a particular proxy solicitation.
DAS does not render any advice or take any action with respect to securities or other property currently
or formerly held in Advisory Accounts or the issuers thereof that become the subject of any legal
proceedings, including bankruptcies and class actions. In addition, DAS generally does not render any
advice or take any action with respect to corporate actions relating to securities held in Advisory
Accounts, including the right to participate in or consent to any distribution, plan or reorganization,
creditors committee, merger, combination, consolidation, liquidation, underwriting or similar plan.
Clients are encouraged to contact the Custodian to ensure that they receive proxy materials and notices
for class actions and other legal proceedings related to the securities in their Advisory Accounts. DAS
recommends that clients promptly review these materials, as they identify important deadlines and may
require action on the client’s part. DAS is not required to notify the Custodian or clients of proxy notices,
shareholder class action lawsuits and similar matters related to securities held in their Advisory Accounts.
Termination of Advisory Relationships Relationships with our clients may be terminated by the Client through the Site or by written notification by
DAS. The termination of a client’s relationship with the Custodian would currently result in the termination
of the client’s participation in the Program and relationship with DAS. Any portion of the Advisory Fee
and other fees due will be deducted from the Advisory Accounts prior to termination.
Privacy The information clients provide to DAS, including clients’ personal information, is subject to the terms of
GS&Co.’s DAS Privacy Policy, which is available on the Site.
Financial Information Not applicable.
SCHEDULE A POTENTIAL EXPENSES NOT COVERED BY THE ADVISORY FEE Below is a list of Apex fees clients may incur that are not included in the Advisory Fee. These fees are incurred only upon request for the service by a client, not DAS, and therefore are excluded from the fees and services covered by the Advisory Fee. Clients will be responsible for the payment of any such fees in accordance with the terms and conditions of such client’s account agreements. This list of fees is the current list of Apex fees, as represented to us by Apex, but Apex reserves the right to modify these fees in the future. Banking: Wire Transfers (Domestic Bank) $25.00 per wire
Wire Transfers (Foreign Bank) $50.00 per wire
Paper Check Draft (USD) Domestic $5.00 per check
Paper Check Draft (USD) International $10.00 per check
Returned Checks / ACH / Wires and Recalls $30.00 per item (Including amendments/repairs)
ACH Notice of Correction $5.00 per notice
Stop Payments on Apex Issued Checks $30.00 each
Check Copies $15.00 each
Third Party Distribution Notification $2.00 per notification
Operations: Postage and Handling (Paper Only)
Confirms $2.00 per confirm
Statements (monthly and quarterly) $5.00 per statement
Paper Tax Statements $5.00 per statement
Historical statements
Requested Data That Cannot Be Retrieved From the SFTP Site or Postage Data:
For Statements From August 2012 and Newer: $150.00/Hour Fee (2 Hour Minimum) (Available
via SFTP
for 60 days)
Account Transfers (full or partial):
Outgoing $75.00 per account
DTC Delivery $25.00 per security
Internal $75.00 per account
TOD Account Transfer Fee $200.00 per transfer
Mailgrams / FINRA Reg T Extensions $25.00 per item
Prepayment, if amount is:
less than $10,000 $20.00
If amount is over $10,000 0.2% of unsettled amount
Overnight Mail – Domestic $50.00 per request
Overnight Mail – International (including Canada) $100.00 per request
Reorganization Activity
Dividend Check $5.00 per item
Domestic Voluntary / Post Actionable Reorgs $50.00 per CUSIP, per Account
International Voluntary / Post Actionable Reorgs $100.00 per CUSIP, per Account
Death Put $100.00 per request
Reorg Physical Processing Fee $125 plus Transfer Agent Fee
Reorg Wire Fee (Domestic) $25.00 each
Reorg Wire Fee (International) $50.00 each
Retirement Plan Services
Short Forced Buy-In Fee $25.00 per ticket
Non-transferable stocks $10.00 per month each
Custodial Account Cancellation Fee $60.00
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