Description of Bartlett & Co. Wealth Management LLC Bartlett & Co. Wealth Management LLC (“Bartlett,” the “Firm,” “we,” “us,” or “or”) is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Bartlett is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because Bartlett is an indirect, wholly- owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Bartlett. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. Bartlett is managed by James B. Hagerty, Brian F. Antenucci, Kyle W. Pohlman, Lori B. Poole, and Holly H. Mazzocca (“Bartlett Principals”), pursuant to a management agreement between and among BDB 1898, LLC and Bartlett. The Bartlett Principals serve as leaders and officers of Bartlett and are responsible for the management, supervision, and oversight of Bartlett. Bartlett’s predecessors, including Bartlett & Co, LLC have a long history of providing asset management services to high-net-worth individuals and families, foundations and endowments, and businesses and institutions. Bartlett’s namesake entity traced its roots to 1898. Bartlett’s advice is almost always provided on a discretionary basis. In some limited instances, mostly legacy situations, Bartlett furnishes investment advice on a nondiscretionary basis. Bartlett also provides comprehensive financial planning services. Types of Advisory Services Wealth Management Services In designing and implementing customized portfolio strategies, Bartlett, as referenced above, generally provides wealth management services on a discretionary basis, with nondiscretionary advisory services being provided in some limited instances. Bartlett provides wealth management services across a broad range of investment strategies and vehicles. Bartlett primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), and individual debt and equity securities in accordance with clients’ stated investment objectives. Bartlett may further recommend to clients that all or a portion of their investment portfolio be managed or advised on a discretionary or nondiscretionary basis by one or more unaffiliated money managers or subadvisors (“External Managers”). Bartlett establishes the client’s investment objectives for the assets managed by External Manager(s), selects the External Manager(s), monitors, and reviews the account performance and, in nondiscretionary arrangements with External Managers, defines any restrictions and places trades for clients. The investment management fees charged by the designated External Manager(s), together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, is exclusive of, and in addition to, the annual advisory fee charged by Bartlett, and will be reflected on the client’s custodial statement. Financial Planning and Consulting Services Bartlett may provide a variety of comprehensive financial planning and consulting services to clients. Such engagements may be part of the investment advisory engagement or pursuant to a separate engagement. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to cash flow analysis, investment planning, retirement planning, estate planning, personal savings, educational savings, and other areas of a client’s financial situation. Bartlett may also provide investment education and customized investment consulting services to clients. A financial plan developed for, or financial consultation rendered to, the client will typically include general recommendations for a course of activity or specific actions to be taken by the client. For example, recommendations may be made that the client start or revise their investment programs, commence, or alter retirement savings, establish education savings and/or charitable giving programs. Bartlett may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Bartlett recommends its own services, as such a recommendation may increase the advisory fees paid to Bartlett. The client is under no obligation to act upon any of the recommendations made by Bartlett under a financial planning or consulting engagement to engage the services of any such recommended professional, including Bartlett itself. Investment Management Services for Qualified Retirement Plans Bartlett provides discretionary investment management services and non-discretionary investment advisory services to clients that include employee benefit plans covered by the Employee Retirement Income Security Act of 1974 and the rules and regulations thereunder (collectively “ERISA”). For ERISA plan clients, Bartlett is typically a “covered service provider” to the plan for purposes of ERISA Section 408(b)(2) regulations. Bartlett provides services to ERISA plans both as a registered investment adviser under the Investment Advisers Act of 1940 (the “Advisers Act”) and as a fiduciary under ERISA. In addition to separate accounts for ERISA clients, Bartlett may serve as an ERISA fiduciary to plans whose assets the Firm manages through wrap fee programs or through certain entities whose assets are treated as plan assets under ERISA. This Brochure provides additional information on the services provided by Bartlett to ERISA plans as well as compensation that the Firm may receive in connection with managing ERISA plan assets. As part of providing discretionary or non-discretionary investment services to ERISA plan clients, Bartlett may provide certain information and services to the ERISA plan client and the ERISA plan client sponsor/trustees. These other services are designed to assist the ERISA plan sponsor/trustees in meeting their management and fiduciary obligations to the ERISA plan. The other services may consist of the following:  Assist with platform provider search and plan set-up;  Plan review;  Plan fee and cost review;  Acting as third-party service

provider liaison;  Plan participant education and communication;  Plan benchmarking;  Assist with plan conversion to new vendor platform; and  Assistance in plan merger. Unaffiliated Broker-Dealer and Investment Adviser Programs From time to time, Bartlett enters into separate agreements with unaffiliated broker-dealers or other investment advisers (“sponsors”) under “wrap-fee” or platform arrangements offered by these sponsors where the client selects Bartlett from among the investment advisers presented to the client by the sponsor. The sponsor has primary responsibility for client communications and service, and Bartlett provides investment management services to the clients. The sponsor generally arranges for payment of Bartlett’s advisory fees on behalf of the client, monitors and evaluates the Firm’s performance, executes the client’s portfolio transactions and, in certain cases, provides custodial services for the client’s assets, all for a single fee paid by the client to the sponsor. Bartlett receives a fee directly from the client. The terms of any fee arrangement are governed by the contract between the sponsor and Bartlett and may differ from the fee schedules shown below. To the extent the single fee also includes transaction costs, clients may pay additional costs if Bartlett executes trades with broker-dealers other than the sponsor of the wrap-fee arrangement or platform. Participation in these arrangements may cost the client more than purchasing such services separately. Client-Tailored Management Services Bartlett provides wealth management services designed to meet a variety of client investment objectives. Client portfolios are managed based on individual clients’ financial situation and investment objectives. Clients may impose reasonable restrictions on the management of their assets if Bartlett determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for Bartlett’s management efforts. Information for ERISA Plan and IRA Clients Bartlett is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plans and ERISA plan participants. Bartlett is also a fiduciary under section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, Bartlett is subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption (a “PTE”). Additional Information Asset Management Services through Pontera When appropriate, we use a third-party platform to facilitate the discretionary management of held away assets. This includes the utilization of Pontera’s order management system to implement asset allocation and rebalancing strategies on behalf of the client. Accounts primarily include defined contribution plan participant accounts, 401(k) accounts, HSAs, and other accounts as defined under ERISA. The platform allows us to avoid deemed custody of client funds as defined by the Securities and Exchange Commission as we do not have direct access to client log-in credentials to effect trades. Bartlett is not affiliated with the platform, and we receive no compensation from Pontera for using their platform. A link will be provided to the client allowing them to connect their account(s) to the platform. Once a client account(s) is connected to the platform, Bartlett will review the current asset allocations. When deemed necessary, Bartlett will rebalance the account considering client investment goals and risk tolerances. The securities utilized by Bartlett for investment in these particular client accounts are limited to the available account options, over which Bartlett has no control. Client account(s) will be reviewed at least annually, and allocation changes will be made as deemed appropriate. Private Funds We recommend certain private investment funds to certain financially qualified clients. The private funds are suitable only for sophisticated investors who do not require immediate liquidity for their investments, for whom an investment in a private fund does not constitute a complete investment program, and who fully understand and are willing to assume the risks involved in the private fund’s investment program. Even where the investments of a private fund are successful, some do not produce a realized return for a period of years. The private funds’ offering documents contain additional information that must be reviewed by any potential investor. Focus Risk Solutions We help our clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of this service and other important information. UPTIQ Credit and Treasury Solutions We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial, LLC (“Flourish”).. Please see Items 5 and 10 for a fuller discussion of these services and other important information. Fiduciary Status As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. Bartlett has a financial interest in the client’s decision to move, add, or allocate assets to accounts for which Bartlett charges a fee for investment management. Bartlett is a fee-only registered investment advisor and is compensated solely from fees paid directly by clients. Bartlett does not accept commissions. Bartlett does not receive any compensation from fund companies or custodians because of trading activities. Please see Item 12 for information regarding certain services and benefits Bartlett receives from Schwab. As of December 31, 2023, Bartlett has $8,402,759,807 in discretionary assets under management in 2,198 relationships; and $38,349,413 in non-discretionary assets in 9 relationships. The total number of relationships is 2,207 and total assets under management of $8,441,109,220.