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TAILORING ADVISORY SERVICES TO THE INDIVIDUAL NEEDS OF THE CLIENTS
Through personal discussions and/or the completion of investment questionnaires, we and the client will agree on
the product(s) in which the client will participate. We will manage each client's account tailored to the investment
guidelines agreed to with the client. We will determine the client’s suability by taking into consideration the client's
financial situation, investment experience, risk tolerance, and investment objectives and/or any reasonable
investment restrictions the client will impose. Investors’ suitability in the private fund we manage is determined in
accordance with both: establishing a pre-existing relationship to understand investment sophistication and the
investor's status as a credited investor prior to completion of the subscription document and admission into the
fund.
At least annually, we will contact or meet with the client to review the portfolio to determine whether there have
been any changes in the client's financial situation or investment objectives and to ascertain whether the client
wishes to impose additional investment restrictions or modify existing restrictions. On a quarterly basis, we will also
contact the client in writing and ask if there have been changes in the client's financial situation or investment
objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. We are
always available to discuss with clients their accounts and individual circumstances.
PARTICIPATION IN WRAP-FEE PROGRAMS
Currently, we provide investment management services as a portfolio manager in the following unaffiliated wrap-
fee programs:
▪ Dual Contract ADV program sponsored by Robert W. Baird & Co Incorporated
In such programs, our investment services are made available to individuals and institutional clients subject to
account minimums specified in the program’s offering brochure. The unaffiliated program sponsor or an
independent financial advisor will work with the client to complete an investment questionnaire and recommend
our investment products (as described above).
When the client selects us as their portfolio manager through the wrap program, we will ask the client to complete
additional documents with us designed to tailor the strategy to the wrap client’s objectives, risk tolerance similar
to what is required of our non-wrap-fee clients, as described above, and whether the client wishes to impose any
reasonable investment restrictions on their account subject to Pier approval. Any client that imposes restrictions
that prevent their account from reaching their investment objective, goal or client target will not be approved as
a firm client. We will manage approved wrap client portfolios according to the strategy they selected and subject
to reasonable account restrictions. We are always available to discuss with clients their accounts and individual
circumstances. Wrap client who also enter into a separate or direct advisory agreement with our firm are treated
like direct non-wrap SMA clients, which among other things includes, at least annual review of investment
suitability investment objectives, risk and whether the client wish to change any existing or impose new
reasonable investment restriction on their account subject to Pier approval as described above.
Please
see item #12 below for additional information regarding our trading and brokerage practices related to
wrap fee programs setting forth any differences in the way we manage wrap vs non-wrap clients’ accounts.
ASSETS UNDER MANAGEMENT
Discretionary assets under our management as of December 31, 2023 amounted to $719,562,120.23.
As of December 31, 2023, we did not have any non-discretionary assets under our management.
FEE SCHEDULE
Pier Capital, LLC charges a management fee for portfolio management services.
The below asset-based fee schedule is designed primarily for Pier’s clients invested in the Small Cap Growth and
Small Cap Growth Concentrated strategies, including the firm’s private fund. The fee schedule for our other
strategies offered may vary from the fee schedule listed in this document.
Account size Annual Fee (%)
First $20 million 1.00%
Next $20 million 0.80%
Next $40 million 0.75%
Above $80 million 0.65%
Certain legacy clients have fee arrangements which are governed by fee schedules different from those listed
above.
Certain client agreements contain Most Favored Nation (MFN) fee clauses. Pier Capital, LLC reserves the right to
reject MFN clauses it deems unreasonable or that are not in line with previous approved MFN arrangements.
Certain clients from a specific family-office with whom our firm has a long-standing relationship are eligible to
participate in our asset-based tiered fee schedule, if the total combined family office relationship assets meet the
account sizes listed in our tiered fee structure. This arrangement allows an opportunity for these clients to receive
a discount to a management fee which would not be possible to attain on a standalone basis.
In some circumstances, including, but not limited to, angel investors in new strategies, existing clients wishing to
add new products and investors of large size, our management fees is negotiable.
Wrap-Fee Programs:
We do not have special fee arrangements for wrap-fee clients. We invoice the client or the program sponsor (if
directed to do so by the client) for our management fee. Typically, we are compensated by a portion of the total
wrap-fee charged by the program sponsor. The wrap-fee collected by a sponsor includes Pier's management fee
and the Wrap sponsors' fee charged for client portfolio transactions without commission (subject to any
restrictions) and custodial services for the client's assets. Certain additional costs can be charged by the wrap-fee
sponsor. For a complete description of the fee arrangement including billing practices and account termination
provisions, clients should review the respective sponsors' wrap-fee brochure.
In evaluating a wrap-fee arrangement, clients should recognize that brokerage commissions for the execution of
transactions in the client's account, if any, are not negotiated by us. Transactions are usually effected 'net’, i.e.,
without commission, and a portion of the wrap-fee is generally considered as being in lieu of commissions. Trades
are generally expected to be executed only with the broker dealer with which the client has entered into the wrap-
fee/directed trading arrangement subject to best execution. The client should also consider that, depending upon
the level of the wrap-fee charged by the broker dealer, the amount of portfolio activity in the client's account, the
value of custodial and other services which are provided under the arrangement, and other factors, the wrap-fee
may or may not exceed the aggregate cost of such services, if they were to be provided separately.