Michael Patrick Flanagan

You’ll pay a fee based on the value of the assets we manage for you, which is calculated and charged quarterly. The annual fee for accounts with $500,000 or more is based on the following tiered fee structure:

• 1.25% on the first $1 million in your account;

• 1.125% on the amount in your account over $1 million and less than or equal to $5 million; and,

• 1.00% on any additional amount in your account over $5 million.

If you establish a relationship with us to manage multiple accounts, accounts with less than $500,000 will be billed at an annual rate of 1.50%. Please refer to our Letter of Agreement for additional information.

Given that our advisory fee is based on total assets we manage for you, we have an incentive to encourage you to increase the amount of assets under our management. You will also generally pay trading commissions or fees to third-party brokerage firms we utilize to custody and make trades for your account. Should we invest in exchange-traded funds or notes, you will pay fees—generally in the form of an expense ratio—to those issuers. Other services we may offer through third parties—such as certain estate or tax planning services—may result in separate charges by those third parties. 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.

When we act as your investment adviser, we have to act in your best interest and not put our interest 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 are some examples to help you understand what this means.

Employee personal account trading
When employees invest for their own accounts, conflicts of interest can arise between the trades we place for clients and the trades employees place in their own accounts. We have adopted a personal account trading policy reasonably designed to address this conflict.

Employee personal accounts managed by FI

When we manage an employee’s personal account, conflicts of interest can arise between the trades we place for client and employee accounts. We have procedures in place so that at no time will proprietary account transactions be placed in any manner such that an employee could benefit at the expense of a client.

The financial professionals responsible for the investment decisions regarding your account (the Investment Policy Committee) receive a combination of base salary and discretionary bonus compensation. Compensation (base salary and discretionary bonus) is based on the individual’s contribution to the firm and firm accomplishments. The financial professionals responsible for servicing your relationship primarily receive a combination of base salary and discretionary bonus. Certain service professionals receive additional compensation tied to the total value of assets you entrust to our management. The financial professionals responsible for introducing our services to you are compensated based on the total value of assets you entrust to our management.