Thomas Charles Pell

Asset-Based Fees: Our asset-based fees for wealth and investment management services range up to 2.00% annually. This fee will be collected on a monthly or quarterly basis and calculated as a percentage of the value of assets we manage as determined in the Client Engagement Agreement we have with you. This presents a conflict of interest as we are financially incentivized to encourage you to place more assets in your advisory account as you will pay more in advisory fees. If you are engaged in our wrap fee program, our asset-based fee will inherently include the costs and securities transaction fees that we pay to third parties and custodians of your assets to perform the services we provide to you.

Fixed Fees: Our fixed project-based fees for stand-alone financial planning, family office, and consultive services are negotiable based on the nature and complexity of the services provided and the overall relationship with us. We will provide you with an estimate of the total cost prior to engaging us for these services. We will collect fees based on your agreement with us.

Performance-Based Fees: We may charge a performance-based fee on assets in certain types of investment accounts that we manage based on the performance of the account as determined in the Client Engagement September 08, 2021 Agreement. This presents a conflict of interest as we are financially incentivized to recommend investments that are riskier or more speculative than might otherwise be the case in the absence of such an arrangement.

Other Fees & Costs: In addition to our advisory fee, you will also be responsible for third party manager fees, custody fees, account administrative fees, fees and expenses related to mutual funds and exchange-traded funds and applicable securities transaction fees. If you are in our wrap fee program, applicable securities transaction fees will be included in our advisory 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. For more detailed information on our fees, please see Item 5 – Fees and Compensation of our Form ADV Part 2A available via our firm’s Investment Adviser Public Disclosure Page.

When we act as your investment adviser, 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 you. Here is an example to help you understand what this means.

We will recommend that you invest in proprietary products that are managed by an affiliate of ours. Investing in a proprietary product means that individuals within our organization will receive additional revenue from the fees collected for the management of these products. We are therefore financially incentivized to recommend that you invest directly into proprietary products over other alternatives. However, you are not obligated to invest in proprietary products in order to maintain an advisory relationship with us.

Additional Information: For more detailed information, please see Item 10 – Financial Industry Activities of our Form ADV Part 2A available via our firm’s Investment Adviser Public Disclosure Page.

Our financial professionals are compensated based on an agreed-upon annual salary and on the revenues generated from the accounts they service. Additionally, they may purchase or receive equity interests in our firm or an affiliate. This means financial professionals have an incentive to increase the asset size in the relationship or solicit new business, taking time away from the day-to-day servicing of current clients.