Smith, Moore and Co.’s (“Smith Moore”) principal location is in Clayton, Missouri and is a
corporation organized under the laws of the State of Missouri. Smith Moore was founded in
1913 and has functioned since that time as a broker-dealer firm registered with the SEC and
the Financial Industry Regulatory Authority (“FINRA”). We became registered with the SEC
as an investment advisory firm in 2007.
Your Smith Moore financial advisor (“advisor”) will collaborate with you to identify your
investment goals, objectives, and risk tolerances to structure an investment account and an
ongoing investment strategy that they believe is most appropriate for you. Smith Moore,
through its advisors, manages assets on a discretionary and non-discretionary basis, for
many diverse types of clients to help meet their financial goals while remaining sensitive to
risk tolerance and time horizons. As a fiduciary it is our duty to always act in the best interest
of our clients. Our firm has established a service-oriented advisory practice with open lines of
communication. Collaborating with clients to understand their investment objectives while
educating them about our process, facilitates the kind of working relationship we value.
The Smith Moore wrap fee program requires clients pay a fee for investment advice of the
financial advisor. Additionally, Smith Moore, the registered investment adviser, charges an
administrative service charge separate from the wrap fee to cover the operational, non-
execution expenses associated with offering the Smith Moore wrap program. Because our
firm assesses this administrative service charge, an incentive exists to promote the
services of the Smith Moore wrap program and to trade in client accounts for the
generation of revenue that directly benefits Smith Moore. These incentives create conflicts
of interests that Smith Moore manages through its compliance oversight program.
In our capacity as an investment adviser, we contract the services of the Royal Bank of
Canada Clearing & Custody (“RBC”) as the custodian of our client accounts. RBC will hold
your investment assets and will issue transaction confirmations and account statements
reflecting the activity in your account. The account(s) will bear certain custodial costs of RBC
as described in Other Types of Fees and Expenses.
Depending on the account of the client or its portfolio trading activity, clients may pay more
for using our wrap fee services than they would for obtaining execution and other services
separately. Your advisor can assist you in obtaining this information on the use of wrap
services as may be necessary.
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 Smith, Moore & Co.
Our Wrap Advisory Services
Portfolio Management:
Our portfolio management service encompasses asset management as well as providing
financial planning and financial consulting to clients. It is designed to assist clients in meeting
their financial goals using financial investments. We conduct at least one, but sometimes more
than one meeting with clients to understand their current financial situation, existing
resources, financial goals, and tolerance for risk to propose an investment account and an
ongoing investment strategy your financial advisor believes is most appropriate for you.
We may propose an investment portfolio, consisting of stocks, mutual funds, exchange-
traded funds (“ETFs”), corporate and government bonds, options and alternative
investments such as limited partnerships, structured products, interval funds and real estate
investment trusts (“REITs”). Upon the client’s agreement to the proposed investment plan,
we work with the client to establish or transfer investment accounts so that we can manage
the client portfolio. Once the relevant accounts are under our management, we review such
accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust
client accounts under our management. If the client experiences any significant changes to
their financial or personal circumstances, it is imperative the client notify us so we can
consider such information in managing the investments and strategy.
Fee Schedule:
a) The minimum and maximum annual fee for investment advice to be charged to the
client’s account(s) will generally range between 0.5% (one-half of a percent) and
3.0% (three percent) and will not exceed 3.0%. The fee to be assessed to each account
will be detailed in the client’s signed advisory agreement with Smith Moore.
b) Our fees are negotiable at our sole discretion. Factors that could affect the amount of
the fees we charge include but are not limited to: (a) the amount of assets to be
managed, (b) the types of investment assets to be managed, (c) the complexity of your
portfolio, and (d) the size and number of other accounts maintained with us by you
and/or your family members.
c) Smith Moore charges our investment management fees “in arrears,” meaning that we
charge our fees after we have provided our services to you. Because our fees are
charged quarterly, they are calculated based on the number of days during the quarter
that our advisory agreement with you was in effect.
d) You provide authorization permitting the calculated fees to be paid by the terms
detailed herein and within your investment advisory
agreement.
e) You are encouraged to review your RBC statements to verify the accuracy of the
calculation of our fees.
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 Smith, Moore & Co.
Smith Moore Administrative Service Fee
In addition to the fee for investment advice by your financial advisor, which is an asset-based
fee, client(s) participating in the Smith Moore wrap program will additionally pay an
administrative service charge. This service charge is retained by Smith Moore and is not
generally an additional form of compensation to your financial advisor. Rather, this fee
supports the operational expenses of Smith Moore in providing the wrap program to its
clients.
This charge is $5.50 and is assessed on a transactional basis for all trade activity within the
wrap program account except in the instances of periodic investment plans (‘PIPs”),
systematic withdrawal investment plans (SWIPs), and same family mutual fund exchanges.
This charge is noted on your trade confirmations for additional clarity and understanding.
Because our firm assesses this administrative service charge, an incentive exists to
promote the services of the Smith Moore wrap program and to trade in client accounts
for the generation of revenue that directly benefits Smith Moore. These incentives create
conflicts of interests that Smith Moore manages through its compliance oversight
program.
Other Types of Fees & Expenses:
In addition to our advisory fees above, Clients may also pay charges imposed by the chosen
investments, charges imposed directly by a mutual fund, index fund, exchange traded fund,
and other investments which shall be disclosed in the fund’s prospectus (i.e., fund
management fees, initial or deferred sales charges, mutual fund sales loads, surrender
charges, variable annuity fees, and other fund expenses). Smith Moore does not receive a
portion of these fees.
Smith Moore does receive compensation as part of their clearing agreement with RBC, from
mutual fund networking fees, annual IRA account fees, bank deposit, margin, money market,
credit interest, margin and credit access line programs.
Smith Moore does not utilize funds that impose 12(b)-1 fees within its wrap program.
In any instance where a 12(b)-1 fee has been assessed to an account within the program,
Smith Moore will ensure a proper refunding event occurs.
RBC will charge additional items related to their services provided as custodian to your
account(s). These charges may include items such as:
Custodial fees.
Transaction-related fees (i.e., wire transfer fees or transfer taxes)
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 7 Smith, Moore & Co.
Credit access line interest
IRA and Qualified Retirement Plan Fees.
Other fees and taxes applicable to certain accounts and transactions.
Mutual Fund Share Class Selection:
Mutual funds typically offer multiple share classes available for investment based upon certain
eligibility and purchase requirements. For instance, in addition to the more commonly offered
retail mutual fund share classes (typically, Class A, B and C shares), mutual funds may also
offer institutional, or advisor share classes (the “lower cost share classes”) or other share
classes designed for purchase in an account enrolled in investment advisory programs. These
lower cost share classes usually have a lower expense ratio than other shares classes. In
addition, lower cost share classes often do not charge a 12(b)-1 fee. Smith Moore will utilize
the most appropriate mutual fund share classes available with RBC for its portfolio allocations
in support of its fiduciary duty to recommend options in the best interest of its client(s). Smith
Moore does not receive or accept 12(b)-1 fees on its advisory accounts and any 12(b)-1 fees
incorrectly received will be rebated back to the affected account(s).
Clients, when participating in our wrap program, should understand that a transaction charge
for mutual fund and exchange traded fund (“ETF”) purchases and redemptions may occur in
accordance with the custodial agreement. The transaction charge varies depending on the
amount of recordkeeping fees received by RBC from the mutual fund or ETF and/or whether
the sponsor of the mutual fund or ETF participates in a No Transaction Fee (“NTF”) Network.
When an NTF mutual fund or ETF is purchased in a client’s account, the NTF fund’s sponsor
directs a payment to RBC on behalf and for the benefit of the client that is used exclusively as
a credit to defray the transaction charge obligations of the client’s account. When an NTF fund
is sold, the custodian / broker-dealer waives the transaction charge to the account. Clients also
should be aware that NTF funds may have higher ongoing internal expenses that can be used to
offset payments made by sponsors for transaction charge waivers, and this can reduce the
investment returns over time relative to other share classes of the same fund.
If the account is being managed directly by an IAR of Smith Moore, the due diligence and
evaluation of share class will be the responsibility of the IAR.
Wrap Fee Program Recommendations
We do not recommend or offer the wrap program services of other providers.
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 8 Smith, Moore & Co.