Description of Services and Fees Santori & Peters, Inc. d/b/a Santori & Peters is a registered investment adviser based in Monroeville, PA. We are organized as an S-corp. under the laws of the State of Pennsylvania. We have been providing investment advisory services since 1985. Ryan P. Neupaver is our firm's principal owner. Currently, we offer the following investment advisory services, which are personalized to each individual client:
•Total Asset Management System
•Pension and Qualified Retirement Planning
•Personal Financial Planning
•Personal Financial Consultation The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. We prepare a financial program for you based on information you provide to our firm. You are responsible for promptly notifying our firm if your financial situation, goals, objectives, or needs change.
As used in this brochure, the words "we", "our" and "us" refer to Santori & Peters and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
Total Asset Management We offer our Total Asset Management to clients who desire a personalized asset allocation program. If you participate in this program, we will develop an individual profile of your cashflow needs; provide an analysis of your financial situation; and recommend specific investments—all of which is available to you through our eMoney platform. We will implement the service through one of our various recommended custodians. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances.
We may recommend that you use the services of a third party investment adviser ("TPA") to manage a portion of your investment portfolio after gathering information about your financial situation and objectives. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPA's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPA(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives. Advisory fees charged by TPAs are separate and apart from our advisory fees and are established and payable in accordance with the brochure provided by each TPA to whom you are referred. These fees may or may not be negotiable. You should review the recommended TPA's brochure and take into consideration the TPA's fees along with our fees to determine the total amount of fees associated with this program. The accumulated fee you pay will never exceed 3% of the total assets under management.
If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing.
Our fee for portfolio management services is based on a percentage of your assets we manage and is set forth in the following fee schedule: Assets under management:Quarterly Fee:Annualized Fee: From $0 - $1,000,0000.250%1.00% $1,000,001 - $2,000,0000.225%0.90% $2,000,001 - $4,000,0000.200%0.80% $4,000,001 - $7,000,0000.175%0.70% $7,000,001 - $10,000,0000.150%0.60% $10,000,001 and above0.125%0.50% Our annual portfolio management fee is billed and payable quarterly in arrears based upon the quarter end asset value. The fee will be calculated by adjusting the quarter end asset value for the flow of assets throughout the quarter by pro-rating all deposits and withdrawals that occur during the quarter. If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances.
We will send you an invoice for the payment of our advisory fee, or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. We will also receive a duplicate copy of your account statements.
You may terminate the portfolio management agreement upon written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the portfolio management agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client.
Please note that at any specific point in time, depending upon perceived or anticipated market conditions/events, we may maintain cash positions for defensive purposes. All cash positions shall be included as part of assets under management for purposes of calculating our advisory fee. (There is no guarantee that such anticipated market conditions/events will occur.) Pension and Qualified Retirement Planning We offer pension consulting services to employee benefit plans on a discretionary basis. The plan provider will adopt a qualified written retirement plan that complies with the legal requirements. We will serve only as an investment advisor. In addition to asset management, our services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting.
If you participate in our discretionary Pension and Qualified Retirement Planning, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory

agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. Pension assets are pooled to determine the percentage of fee assessment. The fee is billed and payable quarterly in arrears based upon the quarter end asset value. The fee will be calculated on a pro-rata basis on all accounts as of the quarter end asset value. The fee schedule is as follows: Assets Under Management: Quarterly Fee:Annualized: From $1 to $1 million 0.250%1.00% From $1,000,001 - $2,000,000 0.150%0.60% From $2,000,001 - $3,000,0000.1375%0.55% From $3,000,001 - $4,000,0000.125%0.50% From $4,000,001 - $5,000,0000.1125%0.45% From $5,000,001 to $6,000,0000.100%0.40% From $6,000,001 to $7,000,0000.100%0.40% From $7,000,001 to $8,000,0000.100%0.40% From $8,000,001 to $9,000,0000.100%0.40% From $9,000,001 to $10,000,0000.075%0.30% Either party to the pension consulting agreement may terminate the agreement upon written notice to the other party. The pension consulting fees will be prorated for the quarter in which the termination notice is given and any unearned fees will be refunded to the client.
Personal Financial Planning We offer financial planning services, which will typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. Once we review and analyze the information you provide to our firm, we will deliver a written analysis or plan to you, designed to help you achieve your stated financial goals and objectives.
You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
We charge a fixed fee for financial planning services, which generally ranges between $2,500 and $10,000. The fee is negotiable depending upon the complexity and scope of the plan, your financial situation, and your objectives. A retainer of one-half of the fee is due at the signing of the Letter of Agreement and credited against the total fees. The balance of the fee is due at the presentation of the finished analysis or plan. We do not require you to pay fees six or more months in advance. Should the engagement last longer than six months between acceptance of financial planning agreement and delivery of the financial plan, any prepaid unearned fees will be promptly returned to you less a pro rata charge for bona fide financial planning services rendered to date.
You may terminate the financial planning agreement within five days of the date of execution and the retainer will be refunded in full. After the initial five days, you may terminate the financial planning agreement by providing written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement. Personal Financial Consultation If you only require advice on a single aspect of your finances, we offer general consulting services on an hourly basis. Our rate for such services is $250 per hour, which is non-negotiable. An estimate of the total time/cost will be determined at the start of the advisory relationship. In limited circumstances, the cost/time could potentially exceed the initial estimate. In such cases, we will notify you and request that you approve the additional fee. Our consulting fee is payable upon completion of the agreed upon consulting services. You may terminate the financial consulting agreement by providing written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement. Types of Investments We primarily offer advice on mutual funds and exchange traded funds ("ETFs"); however, we may also offer advice on equity securities, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, variable annuities, U.S. Government securities, options contracts on securities and commodities, futures contracts on securities and commodities, and interest in partnerships investing in real estate, oil and gas interests, and others.
Additionally, we may advise you on other types of investments that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of 12/31/2023, we manage $330,251,966 in client assets on a discretionary basis. We also manage $148,031,643 in client assets on a non-continuous basis. We do not manage any assets on a non-discretionary basis.