Services
WCG Wealth Advisors, LLC (“Advisor” and “WCG”) d/b/a The Wealth Consulting Group offers asset management
services based on the individual needs of the client. This Brochure describes the advisory services offered under
WCG Wrap Accounts. WCG can participate in wrap fee programs sponsored by other firms and for more
information about Advisor’s other investment advisory services, please contact Advisor for a copy of a similar
brochure that describes such services or go to
www.adviserinfo.sec.gov.
In WCG Wrap Accounts, Advisor provides ongoing investment advice and management of assets in the client’s
account. Advisor provides advice on the purchase and sale of various types of investments, such as mutual funds,
exchange-traded funds (“ETFs”), variable annuity subaccounts, equities, and fixed-income securities. Advisor
provides advice that is tailored to the individual needs of the client based on the investment objective chosen by
the client. Clients may impose restrictions on investing in certain securities or groups of securities by indicating in
the written advisory agreement with Advisor.
Advisor provides management services on a discretionary or non-discretionary basis. The client may authorize the
Advisor to have discretion on the advisory agreement. All accounts are managed by the Investment Adviser
Representative (“IAR”) according to the Investment objective for the accounts. Advisor provides ongoing
supervision over the IAR managing an account.
The IAR may delegate portfolio management responsibilities to the Advisor using one of the Advisor’s model
portfolios. This sub-advisor is a separate offering consisting of portfolio design, investment consulting, trade
execution, and portfolio rebalancing services. The sub-advisor utilizes the account custodian and services are
provided through WCG through a separate written agreement. IARs of Advisor are under no obligation to utilize
these services and WCG Clients who utilize this service are not charged a separate fee. The IARs pay for these
services themselves as a business expense.
Assets for most program accounts are held at LPL Financial (“LPL”), Charles Schwab & Co., Inc., and Fidelity
Brokerage Services, LLC as custodian(s). Other accounts and accounts that are managed by a third party may be
custodied by a separate custodian.
Fees
In WCG Wrap Accounts, clients pay Advisor a single annual advisory fee for advisory services and execution of
transactions. Clients do not pay brokerage commissions, markups, or transaction charges for the execution of
transactions in addition to the advisory fee. The advisory fee is negotiable between the client and the Advisor and
is set out in the advisory agreement. The advisory fee is a percentage based on the value of all assets in the
account, including cash holdings. Advisory fees charged by the Advisor range from 0.25%to 2.50%. Fees for
similarly situated accounts will differ due to the negotiation of the advisory fee with the IAR, the size of the
account, the complexity of the client's servicing needs, long-term or family relationship with the IAR, and
services requested and time commitment. Fees may also be waived for employees or relatives of the advisor.
The advisory fee may be higher than the fee charged by other investment advisers for similar services. The advisory
fee is paid to Advisor and is shared between Advisor and its associated persons. Advisor does not accept
performance-based fees for program accounts.
Asset-Based Fee (“ABF”)
WCG advisors can utilize an Asset-Based Fee (ABF) under all custodians. An ABF is a percentage charge on
the dollar amount of assets in the account in lieu of individual transaction fees on trades executed in the
account. The ABF is in addition to the advisory fee charged by the WCG Financial Advisor and in addition to
the administrative fee (where applicable). The asset-based fees applicable to your account were negotiated
based on the total amount of assets collectively maintained with the custodian of the assets. The ABF is
calculated and paid to the custodian directly each month and is used to cover the transaction expenses to
implement and trade the individual investment positions in the account.
Custodial Transaction-Based Fees. The custodial transaction-based charges are billed by and paid to the
custodian, on trade date, when a transaction is executed through the custodian and is based on the specific
security or investment involved in the transaction. Custodial transaction-based charges are deducted from
WCG’s wrap fee. The custodial transaction-based charges cover various transaction costs, such as mutual fund
fees, brokerage commissions and mark-ups/mark-downs for fixed-income securities.
WCG’s Advisory fees are generally fixed/flat fees. WCG may also utilize a tiered fee schedule with a reduced
percentage rate based on reaching certain thresholds as follows: 1) $0-499,999 1.50%, $500,000 -$999,999 1.25%,
$1,000,000-$1,999,999 1.00%, $2,000,000 - $499,999 0.90%, $5,000,000+starting at 0.80%. and 2) $0-$1,000,000
1.4%, 5 $1,000,000-$2,000,000 1.25%, and $2,000,000 and above 1.%.
It is important to note that the fees charged to clients can vary based on the investment adviser representative
advising the account. An advisor can negotiate the fees at their sole discretion with the client, based on the
complexity of the customer’s situation, the scope of services provided, time commitment, and the experience and
expertise of the advisor. Please note the Advisor may group certain related Client accounts, often known as
“householding”, for the purposes of achieving the minimum account size and determining the annualized fee.
The advisory fee will be disclosed as an “Exhibit A” attached to the investment management agreement. In addition,
fee schedules are set forth by the platform provider and agreed upon and monitored by WCG in their sole discretion
with the client, so long as such fees fall within the ranges approved by the Advisor.
We will bill you for our investment advice through LPL Financials’ billing system, or through our third-party billing
systems. For clients who are billed based on a percentage of account assets, quarter-end fee assessments will be
calculated using one of the following methodologies:
• Using the LPL Financial system, the fee is calculated by taking the value of the account (based on the fair
market value as assessed by the qualified custodian on the last day of the quarter) and multiplying that
value by your advisory fee, the result is then divided by 360, representing days per accounting year and
multiplying that result by the number of days in the month (based on 30 days in the month).
• Using the third-party systems, the fee is calculated the same way except based on 365/366 days per
accounting year and the actual days in the month..
Note: LPL’s quarter-end fee assessment is based on the settlement date and the third-party is based on the
valuations of the last day of the quarter. Because of the different accounting methods, there may be slight
variances in your assessed investment advisory fee. However, both methods are acceptable accounting practices.
If you have any questions regarding the differences in fee calculation methods or how your fees are assessed, you
are highly encouraged to contact WCG for further guidance.
The advisory fee is deducted from the account by the custodian of the assets based on a written authorization
from the client. The custodian calculates and deducts the advisory fee quarterly in advance, in most cases. If the
advisory agreement is terminated before the end of the quarterly period, the client is entitled to a pro-rated refund
of any pre-paid quarterly advisory fee based on the number of days remaining in the quarter after the termination
date.
Generally, advisory fees assessed by WCG do not include the manager's fee, nor does it include brokerage
commissions and other trading costs of transactions (such as mark-ups and mark-downs); mutual fund 12b-l fees;
sub-transfer agent, networking, and omnibus processing fees; transfer taxes, fund management fees, and
administrative servicing fees; certain deferred sales charges on previously purchased mutual funds and other
transaction charges and service fees, IRA and Qualified Retirement Plan fees; administrative servicing fees for trust
accounts; and other taxes and charges required by law or imposed by exchanges or regulatory bodies. Fees for
these platforms are found in the sponsor's or manager's Form ADV.
Further information regarding fees and charges assessed by any mutual funds, variable annuities, and exchange-
traded funds which are passed down to a client are further outlined in the sponsor's or manager's Form ADV, and
in that mutual fund's or annuity's prospectus and other disclosure documents, which are available upon request
by contacting your IAR.
Important information related to the fees for all available investment platforms is described in additional detail
below.
LPL Financial (“LPL”) SWM Platform:
Transaction costs are included in a single fee that covers both advisory fees and transaction costs, the latter of
which is paid by the adviser. As described previously, WCG has the option to negotiate with the custodian for a
flat basis point or flat fee to cover all of the transaction charges or will pay the standard transaction fees. It is
important to remember that the IAR can charge a higher overall advisory fee in order to offset their cost for the
transaction charges involved in the management of the portfolio. Transaction fees vary by broker and/or custodian
and can vary by IAR. Please ask your IAR for details on transaction fees and/or commissions specific to your
account.
The appropriateness of a SWM WRAP account can depend on several factors, including, among other things, client
investment objectives and financial situation, frequency of withdrawals from the accounts, the IAR's investment
strategies and trading patterns including the frequency of trading and the number and size of the transactions.
Clients should consider that depending upon the level of the fee charges, the amount of portfolio activity in their
accounts, the value of services that are provided, and other factors, SWM can exceed the aggregate cost of services
if they were to be provided separately. A transaction-based pricing arrangement can be more cost-effective for
accounts that do not experience frequent trading activity or client withdrawals which would increase the number of
transactions. WCG primarily utilizes mutual funds that are part of the custodian's No- Transaction Fee (NTF)
platform. This platform allows WCG to buy mutual funds without transaction fees being charged to the account.
The client may still pay fees associated with mutual fund family fees that are described in their prospectus and the
custodian's fee disclosure. Although clients do not pay a transaction charge for transactions in a SWM account,
clients should be aware that WCG can pay LPL transaction charges for those transactions. The transaction charges
paid by Advisor vary based on the type of transaction (e.g., mutual fund, equity, or ETF) and for mutual funds
based on whether or not the mutual fund pays 12b-1 fees and/or recordkeeping fees to LPL. Because the Advisor
pays the transaction charges in SWM accounts, there is a conflict of interest in cases where the mutual fund is
offered at both $0 and $26.50. Clients should understand that the cost to WCG of transaction charges may be a
factor that the Advisor considers when deciding which securities to select and how frequently to place transactions
in a SWM account.
In many instances, LPL makes available mutual funds in a SWM account that offer various classes of shares,
including shares designated as Class A Shares and shares designed for advisory programs, which can be titled, for
example, as "Class I," 'institutional," "retail," "service," "administrative" or "platform" share classes ("Platform
Shares"). The Platform Share class offered for a particular mutual fund in SWM in many cases will not be the least
expensive share class that the mutual fund makes available and was selected by LPL in certain cases because the
share class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual
fund. Client should understand that another financial services firm may offer the same mutual fund at a lower
overall cost to the investor than is available through SWM .
Although WCG does not sell Class A share mutual funds, it is important to note that A Shares typically pay LPL a
12b-1 fee for providing brokerage-related services to the mutual funds. Platform Shares are generally not subject to
12b-1 fees. As a result of the different expenses of the mutual fund shares classes, it is generally more expensive for
a client to own Class A Shares than Platform Shares. An investor in Platform Shares will pay lower fees over time
and keep more of his or her own investment returns than an investor who holds Class A Shares of the same fund.
Clients should consider any additional indirect expenses borne as a result of mutual fund fees when negotiating
and discussing with their Advisor the advisory fee for the management of an account.
As noted above, mutual funds are sold with different share classes, which carry different cost structures. Each
available share class is described in the mutual fund's prospectus. When we purchase, or recommend the purchase
of, mutual funds for a client, we select the share class that is deemed to be in the client’s best interest, taking into
consideration cost, tax implications, and other factors. When the fund is available for purchase at net asset value,
we will purchase, or recommend the purchase of, the fund at net asset value. We also review the mutual funds
held in accounts that come under our management to determine whether a more beneficial share class is
available, considering cost, tax implications, and the impact of contingent deferred sales charges.
Other Types of Fees and Charges
Program accounts will incur additional fees and charges from parties other than the Advisor as noted below. These
fees and charges are in addition to the advisory fee paid to Advisor. Advisor does not share in any portion of these
third-party fees.
LPL Financial, as the broker-dealer providing brokerage and execution services on program accounts, and various
custodians will impose certain fees and charges. LPL notifies clients of these charges at account opening and makes
available a list of these fees and charges on its website at
www.lpl.com. The custodian that holds the account will
deduct these fees and charges directly from the client’s program account.
There are other fees and charges that are imposed by other third parties that apply to investments in program
accounts. Some of these fees and charges are described below.
• If a client’s assets are invested in mutual funds or other pooled investment products, clients should be
aware that there will be two layers of advisory fees and expenses for those assets. Client will pay an
advisory fee to the fund manager and other expenses as a shareholder of the fund. Client will also pay
Advisor the advisory fee with respect to those assets. Most of the mutual funds available in the program
may be purchased directly. Therefore, clients could generally avoid the second layer of fees by not using
the management services of an Advisor and by making their own investment decisions.
• Certain mutual funds impose fees and charges such as contingent deferred sales charges, early redemption
fees, and charges for frequent trading. These charges may apply if the client transfers into or purchases
such a fund with the applicable charges in a program account.
Although only no-load and load-waived mutual funds can be purchased in a program account, as noted previously,
the client should understand that some mutual funds pay asset-based sales charges or service fees (e.g., 12b-1
fees) to the custodian with respect to account holdings.
• If a client holds a variable annuity as part of an account, there are mortality, expense, and administrative
charges, fees for additional riders on the contract, and charges for excessive transfers within a calendar
year imposed by the variable annuity sponsor.
Further information regarding fees assessed by a mutual fund, or variable annuity is available in the appropriate
prospectus, which is available upon request from the Advisor or from the product sponsor directly.
Other Important Considerations
• The advisory fee is an ongoing wrap fee for investment advisory services, the execution of transactions,
and other administrative and custodial services. The advisory fee may cost the client more than purchasing
the program services separately,
for example, paying an advisory fee plus commissions for each
transaction in the account. Factors that bear upon the cost of the account in relation to the cost of the
same services purchased separately include the type and size of the account, historical and or expected
size or the number of trades for the account, and number and range of supplementary advisory and client-
related services provided to the client.
• The advisory fee also may cost the client more than if assets were held in a traditional brokerage account.
In a brokerage account, a client is charged a commission for each transaction, and the representative has
no duty to provide ongoing advice with respect to the account. If the client plans to follow a buy-and-hold
strategy for the account or does not wish to purchase ongoing investment advice or management services,
the client should consider opening a brokerage account rather than a program account.
• The Advisor recommending the program to the client receives compensation as a result of the client’s
participation in the program. This compensation includes the advisory fee and also may include other
compensation, such as bonuses, awards, or other things of value offered by LPL Financial to the Advisor
or its associated persons. The amount of this compensation may be more or less than what the Advisor
would receive if the client participated in other LPL Financial programs, and programs of other investment
advisors or paid separately for investment advice, brokerage, and other client services. Therefore, the
Advisor may have a financial incentive to recommend a program account over other programs and
services.
• The investment products available to be purchased in the program can be purchased by clients outside of
a program account, through broker-dealers, or other investment firms not affiliated with Advisor.
Economic Benefits
As a registered investment adviser, we have access to the institutional platform of your account custodian. As such,
we will also have access to research products and services from your account custodian and/or other brokerage
firms. These products are in addition to any benefits or research we pay for with soft dollars, and may include
financial publications, information about particular companies and industries, research software, and other
products or services that provide lawful and appropriate assistance to our firm in the performance of our
investment decision-making responsibilities. Such research products and services are provided to all investment
advisers that utilize the institutional services platforms of these firms and are not considered to be paid for with
soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular
transaction or set of transactions may be greater than the amounts another broker who did not provide research
services or products might charge.
Charles Schwab & Co., Inc.- Institutional
In addition, we receive an economic benefit from Schwab in the form of the support products and services it makes
available to us and other independent investment advisors whose clients maintain their accounts at Schwab. The
availability to us of Schwab's products and services is not based on us giving particular investment advice, such as
buying particular securities for our clients.
Services that Benefit You
Schwab’s institutional brokerage services include access to a broad range of investment products, execution of
securities transactions, and custody of client assets. The investment products available through Schwab include
some to which we might not otherwise have access or that would require a significantly higher minimum initial
investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account.
Services that May Not Directly Benefit You
Schwab also makes available to us other products and services that benefit us but may not directly benefit you or
your account. These products and services assist us in managing and administering our clients’ accounts. They
include investment research, both Schwab’s own and that of third parties. We may use this research to service all
or some substantial number of our client’s accounts, including accounts not maintained at Schwab. In addition to
investment research, Schwab also makes available software and other technology that:
• provide access to client account data (such as duplicate trade confirmations and account statements).
• facilitate trade execution and allocate aggregated trade orders for multiple client accounts.
• provide pricing and other market data; facilitate payment of our fees from our clients’ accounts; and assist
with back-office functions, recordkeeping, and client reporting.
Services that Generally Benefit Only Us
Schwab also offers other services intended to help us manage and further develop our business enterprise. These
services include:
• Educational conferences and events;
• technology, compliance, legal, and business consulting;
• publications and conferences on practice management and business succession;
• access to employee benefits providers, human capital consultants, and insurance providers;
• discount of up to $4,250 on PortfolioCenter® software.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the
services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s
fees. Schwab may also provide us with other benefits such as occasional business entertainment for our personnel.
Fidelity Brokerage Services, LLC
WCG has an arrangement with Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") through which
Fidelity provides WCG with Fidelity's "platform" services. The platform services include, among others, brokerage,
custodial, administrative support, record keeping, and related services that are intended to support firms like WCG
in conducting business and in serving the best interests of their clients. Fidelity charges brokerage commissions and
transaction fees for effecting certain securities transactions (i.e., transactions fees are charged for certain no- load
mutual funds and commissions are charged for individual equity and debt securities transactions). Fidelity enables
WCG to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal
transaction charges. Fidelity's commission rates are generally considered discounted from customary retail
commission rates. However, the commissions and transaction fees charged by Fidelity may be higher or lower than
those charged by other custodians and broker-dealers. As part of the arrangement, Fidelity also makes available to
WCG, at no additional charge, certain research, and brokerage services, including research services obtained by
Fidelity directly from independent research companies, as selected by WCG (within specified parameters).
These research and brokerage services include:
• provide access to client account data (such as trade confirmations and account statements);
• facilitate trade execution and allocate bundled trade orders for multiple client accounts);
• provide research, pricing, and other market data;
• facilitate payment of WCG's fees from its clients' accounts;
• assist with back-office functions, recordkeeping, and client reporting;
• compliance, legal and business consulting; and
• publications, and conferences on practice management and business succession.
As a result of receiving such services for no additional cost, WCG may have an incentive to continue to use or
expand the use of Fidelity's services. WCG examined this potential conflict of interest when it chose to enter into
the relationship with Fidelity and has determined that the relationship is in the best interests of its clients and
satisfies its client obligations, including its duty to seek the best execution. WCG and Fidelity are not affiliated, nor
is there any broker-dealer affiliation between WCG and Fidelity.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as
brokerage services or research.
Retirement Plan Services
WCG Wealth Advisors, LLC is focused on providing advisory services to retirement plan sponsors and individual
participants holding assets in retirement plans. Services provided to retirement plans covered by ERISA will be
identified as WCG Fiduciary Management Services, WCG Fiduciary Consulting Services, or WCG Non-Fiduciary
Services in the Advisory Agreement. Clients are required to execute an Investment Advisory Agreement which will
disclose the details and provisions of the selected retirement plan services.
For services categorized as WCG Fiduciary Management Services, WCG Wealth Advisors, LLC will act as the
Investment Manager as defined by Section 3(38) of ERISA. When providing WCG Fiduciary Management Services,
WCG Wealth Advisors, LLC’s services include discretionary authority to make investment decisions over assets of
a retirement plan. WCG Wealth Advisors, LLC acknowledges that it is a fiduciary with respect to its exercise of
investment decisions over these assets of a retirement plan. WCG Wealth Advisors, LLC acknowledges that in
performing Fiduciary Management, WCG Wealth Advisors, LLC is acting as a “fiduciary” as such term is defined
under Section 3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974 (“ERISA”). WCG Wealth
Advisors, LLC will act in a manner consistent with the requirements of a fiduciary under ERISA for all services for
which WCG Wealth Advisors, LLC is considered a fiduciary under ERISA.
For services categorized as WCG Fiduciary Consulting Services as defined by Section 3(21) of ERISA, all
recommendations of investment options and portfolios will be submitted to the client for the client’s ultimate
approval or rejection. For WCG Fiduciary Consulting Services, the retirement plan sponsor client who elects to
implement any recommendations made by WCG Wealth Advisors, LLC is solely responsible for implementing all
transactions.
WCG Fiduciary Consulting Services are not management services, and WCG Wealth Advisors, LLC does not serve
as administrator or trustee of the retirement plan. WCG Wealth Advisors, LLC does not act as custodian for any
client account or have the authority to initiate third-party disbursements of client funds or securities with the
exception of, for some accounts, having written authorization from the client to deduct our fees.
WCG Wealth Advisors, LLC will act in a manner consistent with the requirements of a fiduciary under ERISA for all
services for which WCG Wealth Advisors, LLC is considered a fiduciary under ERISA. If a retirement plan has elected
to receive WCG Fiduciary Consulting Services and not WCG Fiduciary Management Services, WCG Wealth Advisors,
LLC (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting
management of Client’s retirement plan, (ii) exercise any authority or control respecting management or
disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary
responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan
documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power
to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as
defined in ERISA.
Although an investment advisor is considered a fiduciary under the Investment Advisers Act of 1940 and required
to meet the fiduciary duties as defined by the Advisers Act, the retirement plan services that are identified as Non-
Fiduciary should not be considered fiduciary services for the purposes of ERISA since WCG Wealth Advisors, LLC is
not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact
suite of services provided to a client will be listed and detailed in the Investment Advisory Agreement.
To the extent required by ERISA Regulation Section 2550.408b-2(c), WCG Wealth Advisors, LLC will disclose any
change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv)
as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change
(unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the
information will be disclosed as soon as practicable).
In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), WCG Wealth Advisors, LLC will disclose within
thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator
(unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the
information will be disclosed as soon as practicable) all information related to the Retirement Plan Services
Agreement and any compensation or fees received in connection with that Agreement that is required for the Plan
to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms, and
schedules issued thereunder.
Fees for Retirement Plan Services
For the Retirement Plan Services provided by WCG Wealth Advisors, LLC, clients will be charged a fee as described
in the Advisory Agreement but will not exceed 2.5%. Fees are charged in advance at the beginning of each calendar
quarter. Payments for services are due within thirty (30) days after the quarter's end.
WCG Wealth Advisors, LLC will not be compensated based on capital gains or capital appreciation of the funds held
by the Plan. WCG Wealth Advisors, LLC will not maintain custody of any Plan assets. Clients will authorize any
broker-dealer or mutual fund sponsor that maintains custody of the Plan's assets to automatically deduct all fees
owed to WCG Wealth Advisors, LLC from the Plan's assets and to pay such fees directly to WCG Wealth Advisors,
LLC when they are due. Fees are prorated (based on the number of days services will be provided) for partial billing
periods. If services begin other than on the first day of the quarter, the prorated fee for the initial partial quarter
will be calculated on the total plan(s) value on the last day of that initial calendar quarter, billed in arrears, and
prorated from the effective date of the Agreement. The initial pro-rated fee for the initial partial quarter’s services
will be billed at the same time as the first full quarter’s fees are billed in advance.
WCG Wealth Advisors, LLC believes that its annual fee is reasonable in relation to the services provided and the
fees charged by other retirement plan consultants, including investment advisors, offering similar
services/programs. However, WCG Wealth Advisors, LLC’s annual fee may be higher or lower than that charged by
other consultants offering similar services and programs. In addition to WCG Wealth Advisors, LLC's compensation,
clients will incur charges imposed at the investment level (e.g., mutual fund advisory fees and other fund expenses)
and charges imposed by the Plan’s custodian and Third-Party Administrator (if applicable). Descriptions of mutual
fund fees and expenses are available in each mutual fund prospectus.
The Plan’s custodian or the Third-Party Administrator to the Plan will send statements to the Plan, at least
quarterly, showing all disbursements from the Plan, including, if applicable, the amount of the fee paid to WCG
Wealth Advisors, LLC directly from the Plan and when a such fee is deducted directly from the Plan. Any
discrepancies between fee billing notices received from WCG Wealth Advisors, LLC and the statements received
from the Plan custodian or Third-Party Administrator should be immediately reported to WCG Wealth Advisors,
LLC and/or to the issuer of the account statements (the Plan custodian or Third-Party Administrator).
Brokerage commissions and/or transaction ticket fees charged by the custodian will be billed directly to the client
by the custodian. WCG Wealth Advisors, LLC will not receive any portion of such brokerage commissions or
transaction fees from the custodian or the client.
The fees charged by WCG Wealth Advisors, LLC are in addition to other costs charged by third parties for custodial,
legal, accounting, or record-keeping tasks. In addition, the client may incur certain charges imposed by third parties
other than WCG Wealth Advisors, LLC in connection with investments made through the Plan, including but not
limited to, 12(b)-1 fees and surrender charges, variable annuity fees and surrender charges, and qualified
retirement plan fees.