Rachel M. Luken

Our standard investment management fee schedule is simple, transparent, and based on a percentage of the assets managed. Our fee is calculated and paid quarterly. While the marginal rate decreases when certain asset levels are reached, we are incented to grow your portfolio in alignment with your objectives and to encourage you to increase managed assets. In addition to our fee, you will incur other fees and expenses associated with the management of your portfolio, including brokerage commissions, wire fees, and other transaction fees charged by your custodian. Some investments – such as mutual funds and ETFs, private investments, and separate account managed solutions – have their own built-in fees and expenses for which clients are responsible. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.

Fees for financial counseling services vary and are based on the scope of engagement and complexity of the work. Generally, it is a flat fee negotiated between the client and their advisor. The fee and scope of engagement is memorialized in a Colony-client advisory agreement. For additional details about fees and expenses, please refer to Item 5 (Fees and Compensation) of our ADV Part 2A brochure.

When we act as your investment advisor, we have to act in your best interest and not put our interests ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide to you. Here are some examples to help you understand what this means:

• Custodians – We receive various benefits, including soft dollars and client referrals, from certain custodians. Receiving benefits has the potential to influence our recommendation to clients to use certain custodians over others.

• Margin Accounts – Clients allowing margin in the management of their accounts will be billed on the assets under management, which are not reduced by any indebtedness of the account. This creates a conflict because we have an incentive to recommend that clients allow margin on their accounts rather than selling securities outright for their cash needs.

• Solicitors – We have agreements in place with unaffiliated firms and individuals to refer clients to us in exchange for a portion of the advisory fee we collect from such clients or a fee based on the assets we manage for them. This creates a conflict because solicitors have an incentive to make referrals to us.

• Industry Conferences – We may receive financial support for conference participation in the form of reduced fees, travel/meals, and related expenses from financial industry sponsors such as mutual fund companies. This creates a conflict because we may have an incentive to select those sponsors’ funds for inclusion in our clients’ portfolios.

For more information about conflicts, and how we address them, please refer to our ADV Part 2A brochure.

Our financial professionals are compensated through salary, bonus, and/or a share of our firm’s profits. A portion of that compensation typically is correlated to the amount of client assets they service, the revenue our firm earns from clients, and/or whether the financial professional has increased client assets under our management. We and our affiliates can refer clients to third party services providers, and are also eligible to receive additional compensation for revenues generated through those referrals. Some financial professionals may be compensated by our indirect parent company, Focus Financial Partners, LLC (or one of its affiliates), based on our firm’s revenues or earnings. This gives the financial professional an incentive to encourage you to increase the size of your investment portfolio that we manage. For additional information, please refer to Item 5 of your financial professional’s ADV Part 2B brochure supplement.