Sarah Margaret Westbrook

CAPTRUST advisory fees are asset-based, ongoing, expressed as a percentage of the total assets being managed. We assess fees on a quarterly basis, generally in advance. Fees are negotiated with your Financial Advisor and are documented in your advisory agreement. Accounts can be set up so that your fee rate includes trading cost (called a “wrap fee” program). Wrap fees are asset-based fees that include most transaction costs and brokerage fees charged by the custodian of your account, and therefore, are higher than a typical asset-based advisory fee.

It is important to know that the costs and account types differ. You could pay more for advisory fees if you choose a wrap fee account where the brokerage fees and costs are included in your advisory fee, especially if there is very little trading activity. In general, advisory fees are lower if you choose to pay the cost of transactions separately. Please follow these links information on our wrap fee accounts: CAPTRUST Wrap Fee Programs Brochure or send an email to compliance@captrust.com for a pdf or to have a hard copy mailed to you.

Your account can also be set up so that your advisory fee does not include trading cost (“non-wrap fee”) and you must pay for transactions separately. Click here: CAPTRUST Wealth Client Brochure to review this type of advisory service or send an email to compliance@captrust.com for a pdf or to have a hard copy mailed to you.

Regardless of the which type of arrangement you choose, the more assets there are in your advisory account, the more you will pay in advisory fees, so, we have an incentive to encourage you to increase the assets in your account.

Other types of fees that CAPTRUST may earn: 1) Fixed or Hourly Fees: You can hire us to do a financial plan or analysis for either a flat fee or hourly fee rate. 2) Performance Fees: CAPTRUST may indirectly share in a performance fee in connection to assets invested in 3 private funds for which two CAPTRUST Financial Advisors act as portfolio managers. Please see our disclosure brochures found at https://www.captrust.com/important-disclosures/ for a complete discussion on this conflict. 3) Commissions on life insurance: In a very limited number of cases, CAPTRUST may earns commissions on nonvariable life insurance products when a CAPTRUST Financial Advisor is the insurance agent of record. However, if commissions are paid, you would also not be charged an advisory fee on life insurance.

Other fees and costs related to your advisory account: Separate and apart from advisory fees you pay, here are some of the most common fees and costs applicable to your account: Account maintenance/custodial fees charged by the broker/dealer that holds your account; Management fees related to mutual funds, ETFs, and/or variable annuities, and other transactional fees and product-level fees.

Additional Information: 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.

We are required to act in your best interest which means putting your interest above our own. 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 you. Here are some examples to help you understand what this means: Many CAPTRUST Financial Advisors are licensed insurance agents and registered representatives of our affiliated broker/dealer, CapFinancial Securities, LLC. Those Financial Advisors can earn commissions on life insurance products or, in some instances, commissions on mutual fund or variable annuities. We have a small number of revenue-sharing arrangements with independent third parties. These and other conflicts exist and are disclosed in our Disclosure Brochures found here: Important Disclosures, or you may go to https://www.captrust.com/important-disclosures/. Requests can be sent to compliance@captrust.com.

CAPTRUST Financial Advisors are compensated based upon a portion of the advisory fees paid to CAPTRUST by their clients. Financial Advisors may also earn annual bonuses based on new client assets that come under management or total assets under management. Other CAPTRUST employees (including our Investment Group) are paid salary plus bonuses. In very limited cases, as described under “Other fees”, Financial Advisors may earn commissions on mutual fund, annuities or insurance products or private investments placements. (i.e., differential compensation) when appointed by the client as agent or broker of record.