Fees and Compensation — Form ADV Part 2A (2/20/2026)
[Brochure]
Item 5 Fees and Compensation
Please refer to this brochure's "Advisory Business" section for information on our advisory fees, fee
deduction arrangements, and refund policies.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest in, or recommend that you invest in,
mutual funds, exchange-traded funds ("ETFs"), or money market funds. The fees you pay to our firm
for investment advisory services are separate and distinct from the fees and expenses charged by
mutual funds (described in each fund's prospectus), and ETFs to their shareholders. These fees will
generally include a management fee and other fund expenses. We do not share in any portion of the
fees/transaction charges imposed by the fund managers, nor do we receive any marketing or
distribution fees from the fund managers. You may incur transaction charges and/or brokerage fees
when purchasing or selling specific securities in limited cases. These charges are typically imposed by
the broker-dealer or custodian through whom your account transactions are executed. We do not
share any portion of the brokerage fees/transaction charges imposed by the broker-dealer or
custodian. To fully understand your total costs, you should review all the fees charged by mutual
funds, exchange-traded funds, our firm, and others. Please refer to this brochure's "Brokerage
Practices" section for information on our brokerage practices.
Reporting Fee on Unsupervised Accounts: In certain instances, our clients may wish to include
accounts that are not managed or supervised by Bristlecone in our reports. These accounts may be
held with our primary brokerage relationships or might be held away with other custodians.
Bristlecone will assess a 0.1% annual fee on assets in unsupervised accounts to cover data
processing and reporting costs. We will not charge a reporting fee on any account(s) for which we
have already received an advisory fee.
Account Minimums and Types of Clients — Form ADV Part 2A (2/20/2026)
[Brochure]
Item 7 Types of Clients
We offer investment advisory services to individuals with high net worth and institutions such as
banks and thrift institutions, investment companies, pension and profit-sharing plans, trusts, estates,
charitable organizations, corporations, and other business entities.
We generally require a minimum of $500,000 to open and maintain an advisory account. At our
discretion, we may waive this minimum account size. For example, we may waive the minimum if you
appear to have significant potential for increasing your assets under our management. To meet the
minimum, we may also combine account values for you and your minor children, joint accounts with
your spouse, and other related accounts.