BancWest Investment Services, Inc. (“BWIS,” “Registrant,” “we” or “us”) is registered as an investment adviser with the Securities and Exchange Commission (“SEC”) pursuant to the Investment Advisers Act of 1940, as amended (“Advisers Act”). BWIS is also registered with the SEC as a broker-dealer and is a member of the Financial Industry Regulatory Authority (“FINRA”). BWIS is a wholly owned subsidiary of BMO Harris Bank N.A. (“BMO Harris Bank”) which is a wholly owned subsidiary of BMO Financial Corp. Bank of the West (“BOTW”) is a trade name used by BMO Harris Bank. This information is current as of the date of this Brochure and is subject to change at our discretion. Investment Advisory Solutions (“IAS”) BWIS sponsors various investment advisory programs ("Program" or "Programs"). The Programs described in this Brochure are provided to clients through a “wrap fee” arrangement where the fee is asset‐based, rather than based on the transactions in the account (i.e. commissions). The wrap fee covers advisory, brokerage and custodial services related to the Programs. Such services generally include investment advice or counsel provided by BWIS advisory representatives, professional portfolio management, the execution of client transactions, custody services, account servicing, and performance reporting, in addition to other standard services. BWIS is the sponsor of the following types of Programs: 1. Fund Strategist Portfolios (“FSPs”) 2. Separately Managed Accounts (“SMAs”); and 3. Unified Managed Accounts (“UMAs”). Our Advisory Role With the assistance of an advisory representative, each client completes an investment profile questionnaire (“Questionnaire”) seeking information about the client’s investment objectives, risk tolerance, and time horizon for the assets designated for the advisory account (each, an “Account”). The advisory representative reviews the Questionnaire responses and any other relevant information that a client provides to understand the client’s investment objectives, financial circumstances, investment experience, risk tolerance, and reasonable restrictions the client wishes to impose on management of their assets (collectively, “Client Information”). Our advisory representatives assist clients in analyzing their investment objectives and risk tolerance and making a suitable initial Program selection. The decision to invest in a Program and the ultimate Program selection is solely that of the client. Based on the results of the discussion with the client and responses to the Questionnaire, the advisory representative prepares and reviews with the client a customized Statement of Investment Selection (“SIS”). The SIS incorporates an investment profile summary, summarizes the information the client provided in the Questionnaire and recommends one or more Programs for the client’s portfolio. The client reviews and either approves or rejects the recommendation. If approved, the client executes the SIS, which also specifies the annual Program Fee (defined below) to be charged, and enters into an investment advisory agreement (“Client Agreement”) with BWIS. The Client Agreement discusses the services to be provided to the client and other terms and conditions associated with the Program(s). Clients are responsible for promptly notifying BWIS in writing of any material changes in the information furnished by the client in the Questionnaire or information that is otherwise material to the client’s financial situation, investment objectives, time horizon, risk tolerance and investment strategy or if they wish to impose any reasonable restrictions on the management of their assets. In the event that a client notifies the 5 | P a g e Adviser of changes to the information in their client profile, BWIS will review such changes and recommend any necessary changes to the client’s portfolio. BWIS meets with clients periodically to review the client’s investment goals and current advisory portfolios. The Programs offer clients discretionary investment management. Clients have the option to select which Program and subsequent models or strategies to invest in as described above; however, once selected and agreed upon, clients do not retain day-to-day authority to make investment decisions with respect to the purchases and sales of assets in their Account. The actual investment selection and implementation of client assets is delegated to the appropriate discretionary manager which varies based on the Program selected. In no case does BWIS or its advisory representatives assume any discretionary investment authority in any Program. Clients who participate in a Program establish a brokerage account for which BWIS serves as the introducing broker and Pershing, LLC (“Pershing”) serves as the clearing broker and custodian (collectively, “Brokers”). Clients enter into separate brokerage account agreements directly with BWIS which governs the brokerage services provided. Advisory Roles of Others BWIS receives certain services from other parties that are integral to the advisory services we offer to clients, which includes “Model Providers,” “SMA Managers” and “Overlay Manager.” In the FSP Programs, “Model Providers” construct asset allocation models for a range of client investment objectives and risk tolerances. Model Providers’ work includes research and selection of the portfolios’ individual components, which include mutual funds (“Funds”), exchange traded funds (“ETFs”) and potentially other pooled investment vehicles. Current Model Providers in the FSP Programs include Portfolio Management Consultants (“PMC”), an affiliate of Envestnet Asset Management, Inc. (“Envestnet”), Russell Investment Management Company (“Russell”), Vanguard Advisers, Inc. (“Vanguard”), BlackRock Investment Management, LLC (“BlackRock”), and BOTW’s Investment Strategy and Advisory Team (“ISAT”). ISAT’s parent BMO Harris Bank (in its own name or operating under the trade name Bank of the West) (“BOTW”)), and as such, is affiliated with BWIS. ISAT creates and maintains the Bank of the West Mutual Fund Strategies, the Bank of the West ETF Strategies and the Bank of the West ESG Focused Strategies (“BOTW Models”), as described herein. In the SMA Program, third-party investment managers are referred to as “SMA Managers.” The SMA Managers offered have varying investment objectives, styles, and strategies and invest in varying types of securities to achieve those objectives. The SMA Program has two operational structures for the provision of advice, either: 1) manager traded, where the SMA Manager manages and executes client assets directly or 2) model traded, where the SMA Manager acts as a Model Provider. In Programs where a Model Provider is used, the Model Provider provides its model and any subsequent updates to the model to an “Overlay Manager” who will then implement transactions in the client’s Account in accordance with the Program and/or model selected by the client, subject to reasonable client - imposed investment restrictions. Envestnet currently serves as the Overlay Manager for BWIS. BWIS will provide the ADVs of any Model Providers upon request by the client. BWIS utilizes Envestnet’s advisory, administrative and technological services to make available its advisory programs to BWIS clients. Envestnet is a registered investment adviser, and provides investment management and investment advisory services through independent investment advisers. Envestnet, directly and through its affiliates, also provides proprietary research, an asset management platform, and related technology, 6 | P a g e operational and administrative support services. Envestnet also offers BWIS access to managed investment portfolios chosen from a roster of SMA Managers from a variety of disciplines. Envestnet retains the SMA Managers for portfolio management services through separate agreements entered into between Envestnet and the SMA Manager. PMC also serves as a Model Provider and is part of Envestnet’s portfolio consulting group. Envestnet also makes available the asset allocation strategies developed by the various Model Providers available through the BWIS FSP Programs. If you would like to receive a copy of the Form CRS for any FSP Program Model Provider or SMA Manager, please contact our Client Service Center at 1-800-338-3919. Program Summaries FSP Programs: Bank of the West ESG Focused Model Portfolios. This Program enables clients to invest in a model portfolio of Funds (primarily mutual funds but can at times also include ETFs), representing a range of potential investment objectives constructed by ISAT. The models seek to include, where possible, Funds that apply Environmental, Social, and Governance (ESG) screening as part of their security selection process. While efforts will be made to seek ESG managers for all positions, not every Fund held will include ESG considerations; in situations where a suitable ESG Fund cannot be identified for a certain asset class, it is possible a large percentage of the portfolio will not include ESG Funds. ISAT serves as Model Provider and Envestnet serves as Overlay Manager. After the client has selected a model portfolio representing the account’s investment objective, the rebalancing, reallocating and monitoring of client assets are conducted by Envestnet in accordance with the model. Bank of the West ETF Strategies. This ETF Program enables clients to invest in a model portfolio of ETFs representing a range of potential investment objectives constructed by ISAT. Bank of the West also makes available tax-sensitive versions of the portfolios. ISAT serves as Model Provider and Envestnet serves as Overlay Manager. After the client has selected a model portfolio representing the account’s investment objective, the rebalancing, reallocating and monitoring of client assets are conducted by Envestnet in accordance with the model. Bank of the West Mutual Fund Strategies. This mutual fund model portfolio Program enables clients to invest in a model portfolio of Funds representing a range of potential investment objectives constructed by ISAT. Bank of the West also makes available tax-sensitive versions of the portfolios. ISAT serves as Model Provider and Envestnet serves as Overlay Manager. After the client has selected a model portfolio representing the account’s investment objective, the rebalancing, reallocating and monitoring of client assets are conducted by Envestnet in accordance with the model. BlackRock Multi-Asset Income Model Portfolios. This Program enables clients to invest in a model portfolio of mutual funds and ETFs with an investment objective of generating attractive total return through income and capital appreciation. The models are constructed by BlackRock. BlackRock also makes available tax- aware versions of the portfolios. BlackRock serves as Model Provider and Envestnet serves as Overlay Manager. After the client has selected a model portfolio representing the account’s investment objective, Envestnet conducts the rebalancing, reallocating and monitoring of client assets in accordance with the model. 7 | P a g e BlackRock Target Allocation ESG Model Portfolios. This Program enables clients to invest in a model portfolio of ETFs representing a range of potential investment objectives constructed by BlackRock. The models are managed with respect to certain Environmental, Social, and Governance (“ESG”) objectives by investing in companies with stronger ESG characteristics relative to industry peers. BlackRock serves as Model Provider and Envestnet services as Overlay Manager. After the client has selected a model portfolio representing the account’s investment objective, the rebalancing, reallocating and monitoring of client assets are conducted by Envestnet in accordance with the model. BlackRock Target Income Model Portfolios. This Program enables clients to invest in a model portfolio of fixed income mutual funds and ETFs with a primary investment objective of regular income generation. The models are constructed by BlackRock. BlackRock serves as Model Provider and Envestnet serves as Overlay Manager. After the client has selected a model portfolio representing the account’s investment objective, the rebalancing, reallocating and monitoring of client assets are conducted by Envestnet in accordance with the model. PMC Enhanced Index Strategies. This Program enables clients to invest in a model portfolio of Funds and ETFs representing a range of potential investment objectives constructed by PMC. PMC also makes available tax-sensitive versions of the portfolios. PMC serves as Model Provider and Envestnet serves as Overlay Manager. After the client has selected a model portfolio representing the account’s investment objective, the rebalancing, reallocating and monitoring of client assets are conducted by Envestnet in accordance with the model. PMC ETF Strategies. This ETF Program enables clients to invest in a model portfolio of ETFs (investment companies, whose shares are traded on a stock exchange, that track a specific index or benchmark) representing a range of potential investment objectives constructed by PMC. PMC serves as Model Provider and Envestnet serves as Overlay Manager. After the client has selected a model portfolio representing the account’s investment objective, the rebalancing, reallocating and monitoring of client assets are conducted by Envestnet in accordance with the model. PMC Mutual Fund Strategies. This mutual fund model portfolio Program enables clients to invest in a model portfolio of Funds representing a range of potential investment objectives constructed by PMC. PMC also makes available tax-sensitive versions of the portfolios. PMC serves as Model Provider and Envestnet serves as Overlay Manager. After the client has selected a model portfolio representing the account’s investment objective, the rebalancing, reallocating and monitoring of client assets are conducted by Envestnet in accordance with the model. Russell Model Strategies. This Program enables clients to invest in a model portfolio of Funds constructed by Russell representing a range of investment objectives. Russell also makes available tax- managed versions of the portfolios. Russell serves as Model Provider and Envestnet serves as Overlay Manager. After the client has selected a model portfolio representing the account’s investment objective, the rebalancing, reallocating and monitoring of client assets are conducted by Envestnet in accordance with the model. Vanguard ETF Strategic Model Portfolios– Core Series. This Program enables clients to invest in a model 8 | P a g e portfolio of ETFs representing a range of potential investment objectives constructed by Vanguard. Vanguard serves as Model Provider and Envestnet serves as Overlay Manager. After the client has selected a model portfolio representing the account’s investment objective, the rebalancing, reallocating and monitoring of client assets are conducted by Envestnet in accordance with the model. SMA Program: Separately Managed Accounts. This Program enables clients to invest in third-party investment managers (SMA Managers) that offer varying investment objectives, styles, and strategies and invest in varying types of securities to achieve those objectives. While SMA Managers typically utilize individual stocks, bonds, or a combination of both, certain strategies may employ ETFs or mutual funds for a portion of their portfolio as determined by the SMA Manager. Our advisory representatives assist clients in selecting SMA Managers, typically after reviewing Client Information and materials about the SMA Managers. Depending on the strategy selected, SMA Managers directly implement transactions in accordance with the client’s investment objectives, or serve as a Model Provider, in which case Envestnet serves as Overlay Manager. UMA Program: Unified Managed Accounts. This Program provides clients the ability combine certain FSP Model Providers and certain SMA Managers together, in a single account. Depending on the FSPs and/or SMAs selected by the client for the UMA, the account will contain either Funds, ETFs, individual stocks, bonds and other security types, or a combination thereof, as determined by the FSPs and/or SMA Managers selected. In certain cases, a limited number of individual mutual funds (i.e. those not part of a FSP Model) may also be available as determined by BWIS. The aggregation of the client’s various FSP and/or SMA selections will be used to determine the account’s overall investment objective. The FSPs and/or SMAs in a UMA account will vary depending upon the client’s selection and SMA Manager availability in the UMA Program. The FSPs available in the UMA program serve as Model Providers and Envestnet serves as Overlay Manger. If an SMA Manager is selected, the SMA Manager will either directly implement transactions in accordance with the client’s investment objectives or serve as a Model Provider, in which case Envestnet would serve as Overlay Manager. Rebalancing, reallocating and monitoring of client assets are conducted by Envestnet in accordance with the clients’ UMA selections. Tax Overlay Service Tax Overlay Service is an optional service for UMA accounts that provides a solution for investors who want to customize the realization of embedded gains in their portfolios to minimize adverse tax consequences or who have other unique tax-related circumstances that require an individualized strategy. This service is appropriate for taxable accounts with an equity allocation to stocks of 50% or greater. Any exceptions to this threshold must be reviewed and approved by Envestnet. In order to participate in the Tax Overlay Service, you will need to execute a Tax Overlay Form detailing the tax circumstances related to your account. Envestnet will rely solely upon you for accuracy and completeness of the Tax Overlay Form in order to execute this service. Once elected, the Tax Overlay Service will continue on your account until such time as you provide written instruction to remove your account from the service. If changes to your tax circumstances occur, it is your responsibility to notify BWIS. BWIS does not offer tax advice to clients. Clients should consult with their independent tax advisors as to whether the Tax Overlay Service is beneficial for their particular situation. The performance of accounts employing the tax overlay service can differ, sometimes materially, from like-accounts not using the service. The cost of the service is 10 bps (0.10%) on Program Account assets that utilize the service. This fee is in addition to the Program Fee charged for participating in the IAS Program. In order to participate in the Tax Overlay 9 | P a g e Service the client must provide cost basis information on all positions to be considered for tax management at account opening. If cost basis information is missing or incomplete, Envestnet is not able to manage your account until such time this information is received. This means your account will not be invested until cost basis information is received in good order by Envestnet. If you have elected the Tax Overlay Service for your UMA account you cannot also choose to “pledge” or use the same UMA account assets as collateral for loans obtained through certain affiliated loan programs offered through BWIS’ parent BMO Harris Bank (in its own name or operating under the trade name Bank of the West (“BOTW”)) (see Loans and Collateral under the Additional Considerations section below), given that in the event of a collateral maintenance value exception where all or a portion of your UMA account is required to be liquidated, significant adverse tax consequences could occur. Neither Bank of the West nor BWIS is able to take into consideration any tax mandates agreed to via the Tax Overlay Service when liquidating to cover a maintenance call. Therefore, an account can choose either the Tax Overlay Service or to use the account as collateral for a loan, but not both. Additional Considerations Client-Imposed Investment Restrictions. Clients can impose reasonable restrictions on the management of their Accounts, including that specific securities (or types of securities) should not be purchased or should be sold. This option however, does not permit a client to direct the purchase of specific securities (or types of securities). Any account restrictions could result in the development of a customized asset allocation for the client that deviates from the allocation a Model Provider or SMA Manager would otherwise propose. If the request for restrictions is deemed reasonable by BWIS, applicable Model Providers, SMA Managers and Overlay Manager, replacement securities will be purchased as appropriate. A restriction will be automatically applied across all accounts a client has consolidated for their Program performance report. Restrictions placed on an account could positively or negatively affect account performance and cause the account to perform differently than a like account with no restrictions. Restrictions cannot be implemented on the underlying securities held by pooled investment vehicles (i.e. mutual funds, exchange traded funds, etc.). Clients should promptly notify their BWIS advisory representative of any changes to their investment restrictions. Limited Customization of Model Portfolios. Clients should know that the assets that they designate in each model portfolio Program are likely to be managed in a manner similar to other clients having similar investment objectives and risk tolerance. There are additional limits to the customization of the advice we provide. While non-Program assets are sometimes considered in the formulation of investment recommendations (particularly initial recommendations), generally advice is not offered on those assets and those assets likely will not be taken into account in the course of periodic asset allocation adjustments. Mutual Fund Holdings. Typically mutual fund share classes purchased in Program Accounts are reserved for use in institutional or wrap fee program accounts only, as determined by the respective fund company. Should a client terminate their account from a wrap fee program, any mutual fund holdings will not be automatically liquidated, unless requested by the client. Clients should be aware that any future purchases of the same share class will be impacted and may be rejected once the account is no longer a wrap fee account. Client Rights. Clients retain the right to proceed directly as a security holder against any issuer of any security that constitutes assets and are not obligated to join any person involved in the operation of the Programs or any other client in the Programs as a condition precedent to initiating any such proceeding. Need for Independent Tax Advice. BWIS does not offer tax advice to clients. Investing in our Programs and certain transactions such as liquidating assets and redeeming or exchanging Funds might have tax consequences. Clients should consult with their independent tax advisor prior to investing in our Programs, 10 | P a g e liquidating assets or redeeming or exchanging Funds. Trade Errors. If a trade error is made in a Client’s Account, BWIS will take action to make the account whole. Pursuant to our trade error procedure, BWIS maintains an error account to facilitate handling of trading errors. Gains will be offset by losses in the error account. If an outside investment adviser causes a trade error, the outside investment adviser’s trade error procedure will govern. Loans and Collateral. Upon your written request and with BWIS’ consent, you can “pledge” or use your account assets as collateral for loans obtained through certain affiliated loan programs, such as, but not limited to, the securities-based Investment Line of Credit program (the “Lending Program”). Under the Lending Program, you can receive loan proceeds as a result of an arrangement whereby your account is pledged to BWIS’ parent BMO Harris Bank (in its own name or operating under the trade name Bank of the West (“BOTW”)). The costs associated with such a lending arrangement under the Lending Program are not included in the Program Fees and will result in additional compensation to us and our affiliate(s). In addition, certain BWIS or Bank of the West employees receive financial incentives to recommend these products to clients, which presents a conflict of interest. If you have elected to participate in a Lending Program, the terms and conditions applicable to that Lending Program are governed by the applicable loan documents and other service agreements (collectively “Loan Documents”) and are not included or described further in this Brochure. You should carefully review the terms, conditions, and any related risk disclosures for the Lending Program and understand that such risks are heightened in the event you hold a concentrated position in your pledged Account or if your pledged Account makes up all, or substantially all, of your overall net worth or investable assets. The terms of the Loan Documents could result in the prohibition of purchasing or holding certain assets as collateral which could disrupt your selected Model Provider’s or SMA Manager’s investment strategy for the Account. The terms of the Loan Documents also restrict or prevent withdrawals of assets from your account. Under the terms of the Lending Program, your account is subject to a collateral call or liquidation under certain circumstances. A collateral call or liquidation could prevent your account from being invested in accordance with the model portfolio or your investment objective for a period of time and could disrupt your selected Model Provider or SMA Manager’s investment strategy for the Account. It is possible that you, your advisory representative, or your selected Model Provider or SMA Manager will not receive prior notice of a liquidation of the securities in your pledged Account and will not be entitled to choose the securities which are to be liquidated by the lender. This could result in unforeseeable and/or undesirable tax consequences for which neither Bank of the West nor BancWest Investment Services have any responsibility to consider in making decisions to liquidate assets pledged as collateral. Should you pledge a UMA Account, you cannot also elect the Tax Overlay Service for the account, as neither Bank of the West nor BWIS will take into consideration any tax mandates agreed to via the Tax Overlay Service prior to liquidation and significant adverse tax consequence could occur. Liquidation of certain assets can also result in early termination fees, penalties, and losses not included or described in this brochure. You should consult with your own independent tax advisor in order to fully understand the tax implications associated with pledging your Account as loan collateral and the potential liquidation of pledged assets. You are encouraged to speak with your advisory representative with questions you have about how the Lending Program impacts the investment management and performance of your Account. Wash Sale Restrictions. Wash sale restrictions are enabled for the Program. A wash sale restriction will be automatically applied across all accounts a client has consolidated for their Program performance report. A wash sale restriction ensures the security or substantially same security sold at a loss is not re- purchased within the ‘wash’ period of thirty (30) calendar days. A wash sale restriction expires on the thirty-first (31) calendar day after the security’s sale date. Consult your independent tax advisor for more details. Leveraged and Inverse ETF Restrictions. BWIS does not permit the purchase of leveraged and inverse ETFs in any of its IAS Programs, regardless of whether leveraged or inverse ETFs are part of the SMA Manager or Model Providers’ stated investment objectives. Should an SMA Manager or Model Provider 11 | P a g e attempt to purchase a leveraged or inverse ETF in any IAS Program, the trade will be rejected or the position will be promptly sold. This prohibition can positively or negatively impact your account’s overall performance. Program Fees Each client will be charged an asset-based fee (the “Program Fee”) in exchange for the services provided under each Program. The Program Fee applicable to all open accounts is the Derived Fee Rate (described below). There are no minimum account fees in Program Accounts. Negotiated asset-based fees are available at the discretion of BWIS. Factors involved in this negotiation include, but are not limited to, the nature and size of the overall client relationship with BWIS, the level and type of advisory or other financial services being or expected to be provided, and BWIS’ or its affiliates’ policy with respect to discounts. Unless a lower rate has been negotiated BWIS will charge fees based upon the applicable standard fee schedule detailed below for each Program Account. All Program Fees are annualized and charged on a quarterly basis in arrears based on the Program Account’s average daily fair market value of assets under management during the preceding calendar quarter. In computing the market value of Fund assets, Fund shares are valued at their respective net asset values as calculated in accordance with each Fund’s prospectus. Any such valuation will not be deemed a guarantee of any kind whatsoever with respect to the value of those Fund assets. If a Program Account is opened during any calendar quarter, such account will be billed pro rata in arrears based on the average daily fair market value of assets during the portion of the quarter the account was open. Upon termination of any Program Account, any earned, unpaid fees will be due and payable pro rata. To facilitate this final payment to BWIS, BWIS will calculate an estimated pro-rata advisory fee and withhold cash based on this calculation. Once the final bill is determined by Envestnet and communicated to BWIS, if the cash withheld by BWIS exceeds the amount due BWIS, BWIS will refund any remaining cash balance following the deduction of the final pro-rata

Program Fee. The Program Fee will be deducted directly from the Program Account. In certain situations as approved by BWIS clients may be allowed to deduct fees from another Program Account. The Program Fee depends on the Program option selected and the amount of the client’s assets. The Program Fee is typically assessed at a tiered and blended rate meaning as the total market value of the Program Account assets reaches various thresholds, the asset values above each threshold will be charged successively lower fee rates. This results in a blended effective rate calculated as a percentage of all Program Account assets. The blended effective rate will vary due to fluctuations in market value and changes in asset levels invested (i.e. due to contributions, withdrawals, etc.) and whether the account has been aggregated according to the householding policy described below. Derived Fee Rate Accounts are assessed a fee which includes advisory services offered by BWIS, as well as the execution, clearing, custodial, and reporting services provided by BWIS and Pershing (the “BWIS Fee Rate”). The BWIS Fee Rate does not include, however, the asset-based fee relating to Envestnet’s provision of services under the Programs (“Envestnet Platform Fee”), or the advisory services provided by the Model Providers and SMA Managers participating in our Programs (“Manager Fees”). Together, the BWIS Fee Rate, Envestnet Platform Fee and Manager Fees, are collectively referred to as the “Derived Fee Rate”. Generally neither the Envestnet Platform Fee nor the Manager Fees are negotiable, except in limited situations. The Manager Fees are determined by the relevant Model Providers, SMA Managers and Envestnet, as applicable. The BWIS Fee Rate is negotiable, and differs from client to client, based upon a number of factors, including the total assets invested by a client, assets invested in a related account, the client’s overall relationship with BWIS, and any other factors BWIS deems acceptable. In negotiating the 12 | P a g e BWIS Fee Rate, it is possible that not all factors will be considered or weighted equally among clients. For the purpose of reducing the BWIS Fee Rate, clients can request that their advisory representatives aggregate certain eligible accounts, which include accounts of immediate family members who reside at the same legal address (including a spouse, domestic partner, parent, child, or other dependent). Such client requests to aggregate accounts for purposes of a discounted BWIS Fee Rate are subject to approval by BWIS to confirm account eligibility. Neither BWIS nor its advisory representatives are responsible for identifying accounts eligible for aggregation; clients are solely responsible for identifying the accounts that should be aggregated for purposes of BWIS Fee Rate discounts. In addition, BWIS advisory representatives have the discretion to further negotiate BWIS Fee Rate discounts and to aggregate other accounts not specified above in order to reduce the BWIS Fee Rate. Advisory representatives have aggregated client accounts in the past, which could result in such clients paying a reduced overall BWIS Fee Rate. BWIS and its advisory representatives earn higher fees when a BWIS Fee Rate is not reduced as a result of account aggregation or other negotiated discounts, and BWIS addresses this conflict of interest by disclosing it to clients so that they can discuss the Program Fee with their advisory representatives. ISAT Fees. For its advisory services with respect to BOTW Models, ISAT receives a portion of the BWIS Fee Rate, specifically, 0.15%. The amounts paid to ISAT are included in the overall BWIS Fee Rate paid by clients rather than being in addition to the BWIS Fee Rate clients pay. The standard fee schedule for Accounts subject to the Derived Fee Rate is set forth below. BWIS Fee Rate Value of account assets BWIS Annual Fee Rate First $250,000 1.42% Next $250,000 1.17% Next $500,000 1.02% Next $1,000,000 0.92% Over $2,000,000 0.87% Envestnet Platform Fee. The Envestnet Platform Fee varies based on Program selected and typically ranges from 0.03% - 0.10% of Program Account assets. Manager Fees. The Manager Fee varies based on Program, Model Provider, and SMA Manager selected. FSP Model Provider fees typically range from 0.00% - 0.15% of Program Account assets. SMA Manager Fees typically range from 0.17% - 0.60% of Program Account assets. Envestnet retains a portion of the Manager Fee for its administrative services conducted on behalf of the SMA Managers and Model Providers. Tax Overlay Service Fee. The Envestnet Tax Overlay Service Fee is 0.10% of Program Account assets. This service is optional and the fee is only applied should you elect this service for your account. Householding. BWIS employs a householding policy whereby the market values of certain eligible Program Accounts (“Eligible Accounts”) will be aggregated for fee billing calculation purposes if identified by the methods described below. The aggregation of Eligible Accounts could reduce the effective Program Fee for each Program Account in the household and could result in cost savings to you and other members of your household. If you have Eligible Accounts which you opt out of householding, you will lose this opportunity for potential cost savings. Per our Program Fee schedule, the aggregate market value of your household IAS assets must exceed an average daily balance of $250,000 during the quarter in order to benefit from householding. Eligible Accounts include all Program Accounts of immediate family members who reside at the same legal address (including a spouse, domestic partner, parent, child, or other dependent). In order to help ensure that BWIS households your Eligible Accounts, BWIS requires clients to complete the BWIS 13 | P a g e Investment Advisory Solutions Householding Form (“Householding Form”) provided at account opening and any other time upon request. In addition, effective January 1, 2019, BWIS began conducting internal reviews to automatically identify and link for billing calculation purposes (“auto-household”) accounts that have the same legal address, are eligible for householding and are not already aggregated for billing calculation purposes. This internal BWIS review is conducted on a quarterly basis using a variety of processes in an effort to identify Eligible Program Accounts. Through this process, BWIS will attempt to identify all Eligible Accounts that have the same legal address, however, this is done on a best efforts basis and we make no guarantee BWIS will identify and capture all Eligible Accounts in a household. For instance, BWIS will attempt, but cannot guarantee it will be able to identify accounts with legal addresses in our system of record that are similar but not identical matches. Examples of these situations include, but are not limited to, addresses containing different street address identifiers (example: Street vs St) and situations in which one account address contains an apartment number but another related account does not (example: 123 Main St. Apt 201 vs 123 Main St.). You will not receive any householding benefit until after you have completed the Householding Form, it has been reviewed and accepted by BWIS, and your Eligible Accounts have been linked together by BWIS for billing calculation purposes. BWIS will conduct its own internal review process, as described above, within the last calendar of month of each quarter. If an Eligible Account is opened after that internal review process has begun, your account(s) will not be linked together during that particular billing quarter. This will result in your Eligible Account(s) not receiving any householding benefit until the following quarter. Even though BWIS will take reasonable steps to identify your Eligible Accounts as described previously in this section, clients are ultimately responsible for identifying their Eligible Accounts to be included in a household via the Householding Form. Any householding benefit will be effective for the billing period your Eligible Accounts are linked together and will not be retroactive to any prior time period. Due to privacy concerns, BWIS is not able to disclose the specific account numbers which BWIS has identified and auto-householded using its own internal review processes. However, if additional Eligible Accounts are identified and linked for billing calculation purposes, you will receive a letter notifying you. Clients who would like more information about which of their accounts are householded should contact their advisory representative or our BWIS Client Service Center at 800-338-3919. If you do NOT wish to have your Eligible Accounts Householded, you must notify BWIS by calling your advisory representative or the BWIS Client Service Center at 800-338-3919 and provide written notification listing all of the applicable account numbers to BWIS at 13220 California St. Suite 200, Omaha NE 68154. The auto-householding process does not result in the aggregation of accounts for Quarterly Performance Reporting (“QPR”) purposes. Clients that are auto-householded will still receive separate QPR reports for each account in separate envelopes even if residing at the same legal address. If you wish to receive a single QPR report with your multiple accounts consolidated in a single envelope, you will need to complete a new Householding Form to elect consolidated reporting. In certain situations based on certain settings in the Envestnet system, you will receive consolidated reporting for multiple accounts without requesting it. If you do not wish to have your reports consolidated, please notify your advisory representative. When Program Accounts are householded, all accounts in the household qualify to be billed at a rate based on the average daily market value of the aggregated assets (“aggregate market value”) for all household accounts during a particular quarter. As a result, depending on the aggregate market value of your householded accounts, you could benefit from a reduced Program Fee rate. The aggregate market value of householded accounts must cross the first breakpoint (i.e. $250,000) of the Derived Fee Rate pricing schedule in order to receive any cost savings from householding. 14 | P a g e The following is a simplified householding example: Assume a client has two Eligible Accounts for householding.
• Account 1 = $250,000 market value and Account 2 = $250,000 market value Sample tiered fee schedule: First $250,000 1.50% Next $250,000 1.25% If the two accounts above were not householded, each account would be charged an annual advisory fee of 1.50% based on the market value in each account. If the accounts were householded, the rate for each account would be based on the aggregate market value of the two combined accounts ($500,000). Thus, in accordance with the sample tiered fee schedule above, household assets from $0 to $250,000 would be charged 1.50% and household assets above $250,000 to $500,000 would be charged at the lower rate of 1.25%, resulting in a blended effective rate of 1.375%. Thus, with householding applied, both accounts would be charged a blended effective rate of 1.375% versus the standard rate of 1.50%, resulting in a net cost savings of 0.125%. Based on the $500,000 aggregate market value in this example, householding would result in an annual fee savings of $625 across both accounts. BWIS and its advisory representatives earn higher fees if clients elect not to household Eligible Accounts. BWIS addresses this conflict of interest by providing clients with a Householding Form at account opening, using its best efforts to conduct internal reviews to identify additional accounts that should be householded, and by disclosing this conflict to clients in writing in its ADV brochure so that they could discuss the householding policy or Program Fee with their advisory representative. Affiliated Products. ISAT’s parent BMO Harris Bank (in its own name or operating under the trade name Bank of the West (“BOTW”)), and as such, is affiliated with BWIS. If a client selects a BOTW Model, the portion of fees attributable to BWIS or its affiliate, BOTW (through ISAT), is less than if the client participated in another strategy or Program. As such, BWIS has no financial incentive to encourage clients to select a BOTW Model. For additional information on BWIS’ relationship with ISAT, please read carefully the “Global Investment & Fiduciary Services (GIFS) Investment Strategy and Advisory Team (ISAT) Disclosure Document for BancWest Investment Services (BWIS) Investment Advisory Solutions (IAS) accounts” provided to Program clients participating in a BOTW Model. Additional Information Regarding Program Fees & Related Expenses BWIS and Advisory Representative Fees. We and our advisory representatives receive a portion of the Program Fee paid by clients for the services we provide. The amount paid to BWIS (described above as the BWIS Fee Rate) is the same regardless of which Program is selected and is included in the overall Program Fee paid by clients rather than being in addition to the Program Fee clients pay. Certain advisory representatives are paid based on a portion of the BWIS Fee Rate, while other advisory representatives are paid a base salary and receive an incentive bonus based on their quarterly assets under management (AUM) production. Additionally, these advisory representatives receive additional annual compensation for Program Accounts that remain open for a full calendar year. The amount of this compensation is more than what the advisory representative would receive if the client participated in BWIS’ other programs or paid separately for investment advice, brokerage, and other services. As such, the advisory representative recommending the Program has a financial incentive to recommend the Program over other non-advisory products or services. Additional information about the compensation to BWIS, advisory representatives and BWIS affiliates is discussed below. Fee Reductions and Waivers. BWIS employees and affiliates (including advisory representatives), and members of the families of these persons, are able to participate in the Programs with a reduced Program Fee. 15 | P a g e Additional Fees. In addition to the above fees, there could be postage and per trade handling charges, as well as other charges. The Program Fee does not cover, and the client shall be responsible for: any national securities exchange fees; fees imposed by the SEC, FINRA or other Regulators; charges for transactions not executed through the Brokers; costs associated with exchanging currencies; fees and expenses charged by Funds selected by the client or any investment company in which assets could be invested (as described below); account servicing fees imposed by Pershing; and other fees required by law. As described in the BWIS Fee and Commission schedule provided to all BWIS clients, including Program clients, at account opening, BWIS applies a markup to certain fees above and beyond what Pershing charges BWIS for certain transactions. BWIS determines the amount of markups in its sole and exclusive discretion. The amount of markup varies based on transaction type and typically ranges from $1 - $35. BWIS retains these markups as revenue. Markups are applicable for Full Service and Self-Directed Online accounts only, and not applicable to Investment Advisory Solutions accounts. Program clients are encouraged to carefully review the BWIS Fee and Commission schedule, specifically the “Fees Applicable to ALL Accounts if Incurred” section, for a full list of additional fees that will be applicable to their Program account for certain transactions. In connection with any investment in an American Depositary Receipt (“ADR”), additional expenses and fees could be incurred by the client. ADRs could be subject to dividend withholding taxes from the country of origin, which are an additional expense and reduces the dividend paid to you. In addition, some ADRs are subject to periodic service fees, or "pass-through fees," intended to compensate the agent bank for providing custodial services. Information on any such fees are available in the ADR prospectus. For ADRs that levy this fee, it will be deducted from the dividend, if the company pays one, or it will appear as a separate fee on your monthly statement. Clients should be aware that BWIS passes each assessed financial transaction tax onto affected client accounts. The amount of the tax will be reported on your trade confirmations and brokerage statements. Clients should understand that international or global investment disciplines could invest in securities subject to these transaction taxes. Specific information regarding the additional fees potentially charged for each client’s Account is provided in the brokerage account agreement. Additional Program Fee Information. Program Fees do not include any performance fee or fees based on a share of capital gains or capital appreciation of Program assets. Mutual Fund and Exchange Traded Fund (ETF) Fees. In addition to Program Fees, mutual funds and exchange traded funds (collectively “Funds”) charge separate and distinct fees and expenses (generally referred to as internal fund fees and expenses). Clients owning Funds in a Program will pay these additional fees as Fund shareholders. These fees and expenses are described in each Fund’s prospectus and include, but are not limited to, management fees, shareholder servicing fees, 12b-1 fees, and distribution fees. Clients can and should request and read the Fund’s prospectus before making a decision to participate in any Program purchasing Funds. The Program Fee will be imposed on all Funds held within Program accounts. Prior to investing in a Program, clients should consider carefully any existing Fund holdings on which the client previously paid a sales charge or other fee structure, including cash generated from the sale of a previously held Fund that may have been subject to early redemption fees. Clients could invest directly in Funds outside of the Program, which results in lower fees. In such case, the client would not receive the services provided by us which are designed, among other things, to assist the client in determining which Program, Model Provider(s) and/or SMA Managers are most appropriate for the client’s financial condition and objectives and risk tolerance. Accordingly, clients should review both the fees charged by Funds and the Program Fees to fully understand and compare the fees they would pay by investing in Funds outside of the Program against the fees they would pay by investing through one of the Programs. 16 | P a g e ETFs only offer one class of shares whereas many mutual funds offer more than one class of shares. Specific to mutual fund share class purchases, the FSP Model Providers decide which mutual fund families, mutual funds and share classes they will use to construct their model portfolios. In addition, BWIS allows certain advisory representatives to recommend individual mutual fund positions from a short list of investment options, in which case BWIS works with Pershing and the mutual fund company to determine which share class is eligible for Program accounts. A limited number of SMA Managers may also utilize mutual funds within their strategies, generally referred to as “no-fee completion funds”, providing clients with smaller account sizes access to segments of the market within a SMA vehicle they otherwise would not be able to access to due account minimum constraints. BWIS assists in the oversight of share classes utilized within its IAS Programs through an internal quarterly review process designed to make available the lowest cost share class possible for its IAS clients, subject to certain conditions as described later in this Brochure. It is important to note the expenses of every mutual fund can and will vary over time. Therefore, while BWIS endeavors to identify the lowest cost share classes as described above, in some instances, the share class utilized is not the least expensive share class for a particular mutual fund. Clients may be able to obtain a less expensive share class in other Programs or at another firm. In instances where BWIS receives 12b-1 or shareholder servicing fees from mutual funds utilized in the Program BWIS will rebate or credit client Accounts in an amount equal to any 12b-1 fees or shareholder servicing fees received. Bundled Services and Fees. Clients also should consider that, depending upon the level of the Program Fee charged, the amount of portfolio activity in the client’s Program Account and the value of services which are provided under the Program, the aggregate amount of the Program Fee, which is for bundled services, could total more or less than purchasing the services separately. Clients could obtain some or all of the types of services available through the Programs from other firms, and fees could be higher or lower for comparable services, assuming such services are available. Clients are responsible for reviewing other services or investments available with their advisory representatives to determine whether they would be more appropriate than the Programs offered in this Brochure. In comparing the relative costs, clients should consider various factors, including, but not limited to:
• Client preference for an advisory or brokerage relationship;
• Client preference for a fee-based or commission-based relationship;
• Investment products available from each service;
• Whether a particular investment strategy is available through another BWIS program or service;
• The amount of trading activity expected in the client account;
• The amount of assets expected to be allocated to cash;
• The frequency and type of client-profiling reports, performance reporting and account reviews available in each product or service;
• Historical or expected size of the account Account Funding. Program accounts can be funded with cash, securities or both. Securities transferred into a Program account will be sold on behalf of the client without regard to potential tax implications and the proceeds invested into the strategy selected for the account. If clients elect a dollar cost averaging (DCA) strategy and choose to invest their account over time according to an agreed upon schedule, any cash in the Program account that is not invested is included in the billing calculation of the account. Non-Program Assets and Unsupervised Assets. Non-Program assets are not allowed to be held in Program Accounts. The purchase and sale of assets to be held in a Program account is at the discretion of the Model Provider or SMA Manager. This means, any non-Program assets you transfer into a Program account can be sold at any time without regard to potential tax implications, and the proceeds of which invested into the strategy selected for the account. BWIS, at its sole discretion, can allow a non-Program asset to be held in a Program account and designate that asset as “unsupervised”. If such accommodation is made, the unsupervised asset is excluded from billing, reporting, and trading. BWIS has no obligation to provide advice 17 | P a g e or oversight of unsupervised assets and is not responsible for performance of such types of assets. Billing on cash. All cash and cash equivalents held in a Program account are considered part of the Program account assets and are included in the billing calculation. This includes but is not limited to a small cash position that is maintained in all Program accounts at all times in addition to any cash raised in a Program account as requested by the client or held for other reasons. If you hold cash in your Program account, it will be included in the billing calculation. We encourage clients who raise cash in their Program account to take action and move the cash out of their Program account as soon as practicable. UMA Billing Methodology for Manager Sleeves. For UMA accounts, BWIS utilizes Envestnet’s ‘Target’ billing methodology to calculate the billable value for each manager sleeve within the account. This methodology uses the target percentage for each manager that is reflected on the client’s Statement of Investment Selection and then multiplies it by the total billable value of the account to determine the value upon which the Manager Fee for that sleeve will be assessed. Trading Away, Step-out Trades and Additional Trading Costs. BWIS refers to trading away, also known as step-out trading, when a third-party investment advisor executes trade orders with a broker/dealer or exchange other than Pershing, LLC (BWIS’ clearing broker and custodian) generally in an effort to seek best execution quality on a trade. In the BWIS IAS programs, both the SMA and UMA programs offer access to third-party investment advisers (“Managers”). Manager- traded strategies have the ability to perform step out trades whereas Model-Provider trades are conducted by Envestnet which directs all trades through Pershing. You will not pay any additional trading costs when the Manager uses Pershing to execute a trade in your account. However, if the Manager engages in step-out trading, you can incur transaction costs in addition to the Program Fees you pay. In some instances, step-out trades are executed without any additional transaction costs from the executing third-party broker/dealer. In other instances, the Manager chooses to perform step-out trades even if the client will incur additional transaction costs. It is important to note any transaction costs incurred by clients for trading away is in addition to the Program Fee assessed by BWIS for a client’s participation in the IAS program. Such additional transaction costs can be in the form of a commission, markup or markdown on the trade, embedded into the price of the security, and passed onto clients via the price paid for the security (i.e. net purchase or sale price). The net purchase price of a security is reflected on the trade confirmation clients receive for the particular step-out trade, however, these additional transaction costs are generally not itemized separately on client trade confirmations or brokerage statements, and thus make it difficult for investors to discern the amount of the commission, markup or markdown on the trade. The number of trades placed as step-out trades varies depending on the Manager involved. Selecting a Manager who does a significant number of step-out trades can result in higher fees and costs than a Manager who primarily places trades with Pershing for execution. Before selecting a Manager, you should consult the Manager’s ADV for information about their trading practices and costs. In addition, please read carefully BWIS’ “Investment Manager Trading Away/Step-Out Trading, Trade Rotation and Trade Aggregation Practices on Investment Advisory Solutions (IAS) Program Accounts” disclosure document provided to all clients participating in the SMA and UMA Programs prior to investing. This document provides a list of Managers available in the IAS program who are performing, or have the potential to perform, step out trades. Trade Rotation. Third-party managers typically manage other wrap fee accounts employing the same or similar strategies for multiple advisors, sponsors, or custodians, and also manage independent client accounts side-by-side with wrap fee accounts. Third-party managers employ a trade rotation process in which one group of clients has a transaction effected before or after another group of clients. These trade rotation practices are designed to minimize the impact of their trading on the securities or markets in which they trade. However, these trade rotation practices can result in a transaction being effected for your account near or at the end of the third-party manager’s rotation, causing your account to bear the market price impact, if any, of those trades executed earlier in the rotation. This could result in your account receiving a less favorable net price for that particular trade. However, the third-party manager’s trade rotation policies are typically 18 | P a g e designed to ensure that the order used in the rotation varies from trade to trade and that clients are treated fairly and equitably over time. Before selecting a Manager, you should review the Manager’s ADV for more information. In addition, please read carefully BWIS’ “Investment Manager Trading Away/Step-Out Trading, Trade Rotation and Trade Aggregation Practices on Investment Advisory Solutions (IAS) Program Accounts” disclosure document provided to all clients participating in the SMA and UMA Programs prior to investing. Trade Aggregation. At times, manager-traded SMA strategies may place orders to purchase or sell the same security for a number of clients invested in a particular investment strategy. An SMA Manager may decide to aggregate such trades into a block trade that is executed through a single broker/dealer versus effecting individual trades through a single or number of different broker/dealers in an attempt to obtain a more favorable execution than would otherwise be available if the trades were not aggregated. If an aggregated order is executed, the SMA Manager is responsible for allocating those trades to clients in a fair and equitable manner. With respect to accounts having ESG or socially responsible investment guidelines or other restrictions, it is possible that these accounts will not be included in the manager’s block trade. Often times, a manager’s initial purchase of a security in an account with ESG or socially responsible investment guidelines will occur after similar trading has been executed for the accounts participating in the block trade. In cases when a trade for a particular security occurs after a block trade, the accounts that are traded outside of the block will receive different terms for trades in the same or similar securities, which terms can be less advantageous than those received by the larger block trade. Similarly, the block trade itself generally will disadvantage client accounts that are traded outside of the block.