With one notable exception, our cost disclosure requirements for the annual cost control process conform to the same rules as for the offer submission process.

The only difference is that for the annual cost control, we require you to report the total of all costs, including one-off costs, not just the total of ongoing costs.

The overarching principle is to create transparency about costs and hence to disclose the total annual cost to the client. This includes all direct and indirect costs, as well as external costs incurred by third parties who may be part of your product setup. Our disclosure requirements thus may go beyond what is required by GIPS or by law.

Again, for annual cost controlling purposes, total annual cost does include one-off costs such as subscription and redemption fees, the initial cost of building up a portfolio at inception, commitment fees, or any other kind of cost that was incurred in the relevant reporting period.

The rationale for including one-off costs for annual cost control but not for offer submission purposes is that our RFP process is designed to ensure comparability of costs incurred during the long-term, while the annual cost control is focusing on the most recent time period to ensure that no undue cost was incurred, irrespective of the age of a portfolio.

Performance Fee

If you charge a performance fee, please disclose that you do and explain its mechanism such as high-water mark, hurdle rate, etc.

Custody

• All costs of custody, including those charged by the custodian himself and by third-party custodians.
• If you are offering an all-in custody fee model, please enter the all-in custody fee here.
  

Transactions

• All non-refundable costs of trading, such as brokerage, commissions, exchange fees, or non-refundable taxes charged both by your own firm and by third parties.
• Please do not include recoverable taxes such as withholding taxes.

Management

• All management and/or advisory fees.
• If performance fees apply, please add their annualized impact to management fees.
  
• If you are offering an all-in fee, please enter it here. Please ensure to add all costs not included in the all-in fee in the appropriate cost disclosure fields.
  

Product

• All explicit and implicit product costs e.g. Ongoing Cost (formerly Ongoing Charges, TER) of funds, structured products and other products used in the portfolio, including the cost of transactions and performance fees of those products.
• Please do not split up your product cost across the other categories, especially if you are offering a fund or other product.

Other

Any other costs not included in any of the categories above (e.g. account fees, fees for tax reports, costs incurred by any other third parties such as pension foundation fees, etc.).

Granted Discount

If you are offering an exclusive discount for ZWEI clients:

• Quote all cost components of your offer net of the discount.
• Use the granted discount field to indicate the absolute total percentage point reduction across all cost components (not the share of the discount relative to your normal fee). E.g. if your ordinary management fee is 0.70%, and the discounted fee that is available exclusively to clients of ZWEI Wealth is 0.50%, then the granted discount is 0.20%.