During the second quarter of 2018, Colonial began to offer a fully discretionary investment-management service to provide options that better suit the investment-committee governance needs of new and existing clients. All Colonial clients will have the option of selecting non-discretionary advisory or discretionary management services associated with the investment decision-making process and/or the administrative tasks associated with implementing an institutional investment portfolio.
Colonial will not hold client funds directly. At the same time, Colonial will be deemed to have constructive custody of client funds and will undergo surprise examinations conducted in accordance with Rule 206(4)-2 of the Investment Advisers Act of 1940.
Colonial Consulting has been focused on avoiding conflicts of interest since its inception and we take seriously the fiduciary responsibility we owe to our clients. We consider the best way for Colonial to reduce the perceived conflict in investment decision-making under both the advisory and discretionary management models is to charge the same fee for the investment decision-making aspects of both models. Accordingly, new clients that select Colonial to provide discretionary investment management will pay a management fee for such investment advice pursuant to the same fee schedule as a new client selecting non-discretionary advisory consulting. The administrative fee referenced above would be an additional charge for the transaction execution.