John Patrick Niles

Our annual advisory fee is generally based upon a percentage of the market value of assets placed under our management. Fees may vary based on asset size, and the nature and complexity of each client’s particular needs. Our advisory fee is inclusive of all of our wealth management services. Our standard annual advisory fee begins at 0.65% and declines based on assets under our management, thereby reducing the fee rate payable to us. We generally charge an administration fee in our administered private investment vehicles, and we charge a unitary management fee in BBR ALO Fund, LLC, as further described in our Form ADV Part 2A. Our advisory fee is prorated and invoiced quarterly, in arrears.

Because our advisory fee is based on the amount of your assets under our management, the more assets you entrust us to manage or the more your assets grow, the more you will pay us for our services. Therefore, we have an incentive to encourage you to increase the amount of assets that you entrust to us.

Your account will be held with a qualified custodian of your choice. Custodians may charge transaction fees for effecting certain securities transactions. In addition, your assets can be invested in pooled investment vehicles and/or separately managed accounts. You will bear your pro rata share of the investment management fees and other fees of these investments, which are in addition to the fees you pay us. For pooled investment vehicles, these fees and expenses are described in each fund’s prospectus or offering document and potentially include a management fee and other fund expenses. 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 about our fees and costs related to our management of your account, please See Item 5 in our Form ADV Part 2A.

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 that we provide you. Here are some examples to help you understand what this means:

• We may recommend rollovers out of employer-sponsored retirement plans and into Individual Retirement Accounts that we manage for an asset-based fee. If we don’t currently manage your account held with your employer’s plan, this will increase our compensation.

• We may recommend that you invest in the BBR Funds for which we or our affiliates generally receive fees, separate from our advisory fee. The recommendation that you invest in a BBR Fund presents a conflict of interest. In order to mitigate this conflict of interest, we disclose to each client the costs, benefits and implications of investing in a BBR Fund with respect to a client’s investment objectives. You are not under any obligation to invest in these vehicles.

• Members of our Investment Committee have been asked to serve on advisory boards of certain unaffiliated investment managers to which we have allocated, and anticipate that we will continue to allocate, client investment assets. These arrangements create conflicts of interest. For more information on these arrangements and how we seek to mitigate these conflicts of interest, please review Item 10 of our Form ADV Part 2A.

For more detailed information about our conflicts of interest, please review Item 4, 11 and 12 of our Form ADV Part 2A.

Our financial professionals are generally compensated on a salary basis and may receive discretionary bonuses. In the event an employee earns a bonus, it is based on various factors. In addition, certain of our financial professionals are equity owners of the firm, in which case they stand to receive a share of the profits of the firm.