I have a quick question about charging asset based fees to clients. I think providing an example would help in explaining my concern: an investor has $200k in an IRA/taxable account and $300k in a 403(b). Can I charge, say 1%, on all $500k and then deduct it from the IRA/taxable account or can I only charge 1% on the $200k and not advise on the 403(b)? Thanks for your input.
Definitely do not take my comment as a legal opinion, but my understanding is that you must be consistent in all of your practices. So if you are charging 1% on ALL assets under management (500K in this case) you may do so but you must do the same for all clients having both types of accounts. Further this must be clearly stated in your ADV FORMS.