Nicholas Winter

For investment advisory services we charge a fee based on assets we manage. This is billed on a quarterly basis. For an asset-based fee, the more assets that are in a client’s advisory account, the more a client will pay in fees. Therefore, we may have an incentive to encourage clients to increase the assets in his or her account. For standalone financial planning services, we charge a first-year fixed fee and annual fixed fee. The first-year fixed fee is billed one half (50%) at the beginning of the engagement and one half (50%) at your receipt of the written financial plan. The subsequent ongoing annual fixed fee is billed monthly unless otherwise negotiated with the client.

In addition to Bartlett’s fees you will be responsible for other fees and expenses, such as transaction charges and fees/expenses charged by any custodian of your account, subadvisor, mutual fund, exchange traded fund, separate account manager and any taxes or fees required by federal or state law.

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 additional information, see Item 5 Fees and Compensation of our Form ADV Part 2A Brochure. Brochure available online at adviserinfo.sec.gov/firm/summary/292246.

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 to you. For example, we receive various benefits and services from custodians that we may recommend to you, and we utilize unaffiliated third-party solicitors to solicit prospective clients and pay such solicitors a percentage of the fees earned from these solicited clients. For additional information, please refer to our Form ADV Part 2A Brochure, specifically Item 5 Fees and Compensation, Item 10 Other Financial Industry Activities and Affiliations, Item 12 Brokerage Practices, and Item 14 Client Referrals and Other Compensation. Brochure available online at adviserinfo.sec.gov/firm/summary/292246.

Our financial professionals are paid pursuant to a combination of salary and a bonus structure. The bonus structure takes into consideration factors such as the amount of client assets they service, new clients obtained and/or an increase in client assets supervised by the professional, the time and complexity required to meet a client’s needs, and the individual’s contributions to the success of the firm during the course of the year. This creates a conflict of interest since the firm charges an asset-based advisory services fee, and the more assets you have in your account the more you will pay in fees and, therefore, the firm and the financial professional have an incentive to encourage you to increase the assets in your account. A number of our financial advisors may be eligible for additional compensation from our indirect parent company, Focus Financial Partners, LLC (or one of its affiliates), depending on the performance of Bartlett. Eligibility will be determined based on all or a portion of Bartlett’s annual revenues and earnings. This potential for increased compensation provides an incentive for these financial advisors to encourage you to maintain and even increase the size of your investment account with us. See Item 5 of your financial advisor’s Form ADV Part 2B Brochure Supplement for more information about your individual financial advisor’s compensation. Brochure available online at adviserinfo.sec.gov/firm/summary/292246.