FCAM oversees clients’ portfolios based upon the client’s risk profile, investment horizon, financial goals, income (current and potential), tax bracket, portfolio size, net worth, and other aspects of the client’s financial profile. The FCAM WRAP Program consists of three programs all of which are offered as “wrap account” programs which bundle advisory, administrative, and transaction charges into one asset-based fee. A portion of the wrap fee is allocated to the administrative fee, which covers administrative and supervisory services provided by FCAM as well as transaction, execution, clearing and custodial services as provided by a third-party clearing firm. FCAM also receives a portion of the fee for advisory services. Clients should consider that depending upon the level of the wrap fee charges, the amount of portfolio activity in their accounts, the value of services that are provided under these programs, and other factors, the wrap fee may or may not exceed the aggregate cost of services if they were to be provided separately. Under a wrap account program, your assets would be managed by FCAM generally in the same manner as assets managed by FCAM for clients not in a wrap account program other than the requirements or restrictions of the program, although this would be subject to your particular investment needs and objectives. FCAM does not offer wrap programs to new clients. Existing clients may add additional funds as needed. Clients are billed the asset-based fee in advance based upon the assets under management on either a monthly or quarterly basis, depending upon the program chosen. The timing of such billing is determined, in part, by the particular investment program chosen by the registered investment advisor along with the client. Details of fees, as well as the timing of such fees, will be discussed and disclosed in the client agreement prior to opening an account. FCAM WRAP Program Fee Schedule Account Size Maximum Fee $50,000 - $100,000 2.00% $100,001 - $200,000 1.75% $200,001 - $500,000 1.25% $500,001 AND ABOVE 1.00% These fee amounts may be negotiated depending upon circumstances including but not limited to account composition and complexity, account size, employee or family relationships, etc. which may result in different fees being charged by us for client accounts similar in composition and objectives. You should understand that mutual funds, including exchange traded funds and similar investment products, in which your assets are invested by us or by others, impose separate investment management fees and other operating expenses (described in the fund’s prospectus) for which you will be charged separately from the fee paid to us for our services. The tiered fee schedule above is assessed for each account, and FCAM does not aggregate other accounts for the client (Householding) when determining the fee. FIRST CITIZENS ASSET MANAGEMENT, INC. WRAP BROCHURE Page 5 of 13 FCAM utilizes money market funds as temporary investment vehicles for clients as permitted by law and subject to applicable restrictions. The use of money market funds in “sweep” arrangements, for temporary investment purposes or otherwise, may result in FCAM earning advisory, distribution or other fees described herein. The fees earned by

FCAM may vary depending on the money market funds utilized. FCAM is not compensated based on a share of capital gains or capital appreciation in a client’s account or any portion thereof. The client will grant FCAM the authority to receive monthly or quarterly fee payments directly from the client’s account held by an independent custodian. The client provides limited authorization to withdraw the contractually agreed upon fees from the account. The custodian of the account is made aware of the limitation of FCAM’s access to the account. The custodian sends the client a statement, at least quarterly, indicating all the amounts disbursed from the account including the amount of advisory fees paid directly to Advisor which the client should verify for accuracy as to our fee calculation. The custodian of the account holds all customer assets. FCAM does not physically hold or handle customer funds or securities. The management, certain support staff and the Advisors of FCAM are also registered representatives of FCIS., a securities broker-dealer. You may work with your Advisor in his or her separate capacity as a broker dealer registered representative of FCIS. When acting in his or her separate capacity as a registered representative, your Advisor may sell securities such as stocks, bonds, mutual funds, and exchange-traded funds to you on a commission basis. As such, your Advisor may suggest that you implement investment advice by purchasing securities products through a commission-based brokerage account in addition to or in lieu of a fee-based investment- advisory account. This receipt of commissions creates an incentive to recommend those products for which your Advisor will receive a commission in his or her separate capacity as a registered representative of a securities broker-dealer. Consequently, the objectivity of the advice rendered to you could be biased. As described elsewhere in this Brochure, FCAM receives 12b-1 (distribution) fees for the sale of certain mutual funds purchased by advisory clients. Client assets are sometimes invested in shares of registered funds (such as mutual funds) that offer several classes of shares with different fees. Some share classes charge 12b-1 (distribution) fees, shareholder services fees or administrative fees and pay these fees to FCAM. Distribution payments, or 12b-1 fees, compensate FCAM for selling registered fund shares. Shareholder services and administrative fees compensate FCAM for customer account services and administration such as account and trade detail recordkeeping, customer statement preparation and delivery, tax reporting, and other services that the registered mutual fund otherwise would have provided. Distribution, shareholder services and administrative fees are deducted from the mutual fund’s assets and indirectly paid by the fund’s shareholders. Registered funds often offer one or more share classes that do not charge 12b-1 or shareholder services fees. Clients may be able to invest in lower-cost share classes directly. FIRST CITIZENS ASSET MANAGEMENT, INC. WRAP BROCHURE Page 6 of 13 FCAM does endeavor to invest client funds in the cheapest available share class. Also, in situations where the cheapest share class still pays a 12b-1 fee to FCAM, we will refund/credit these fees back to the client.