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S FIDELITY WEALTH ADVISOR SOLUTION ® REFERRAL AGREEMENT AND ACKNOWLEDGMENT Please keep a copy of this Referral Agreement and Acknowledgement (the “Agreement”) for your records. Fidelity Wealth Advisor Solutions (“WAS” or the “Service”) is a referral service of Strategic Advisers LLC (“Strategic” and, together with its affiliates, “Fidelity Investments”), a registered investment adviser and Fidelity Investments company. The Service is designed for current and prospective clients of Fidelity Investments and other investors who seek to receive referrals to third party independent investment advisory firms (each an “Advisor”). As part of these referrals, Strategic is required to provide you with certain information regarding WAS and your Advisor is required to obtain your acknowledgement of your receipt of this information. By signing this Agreement, you hereby acknowledge and agree that: 1. Neither Strategic nor any other Fidelity Investments company is affiliated in any way with the Advisors that participate in the Service, and no Advisor has authority to act for or obligate Strategic Advisor's investment products or services or investment performance, or the appropriateness of any particular advisory service for your particular circumstances. or its affiliates or to make any representations on their behalf. Advisors are customers of affiliates of Strategic, including Fidelity Brokerage Services LLC (“FBS”) and National Financial Services LLC (“NFS”), and such affiliates receive compensation from Advisors’ customers for the clearing, custody and other brokerage services associated with any accounts held with such affiliates. 2. Each Advisor’s inclusion in the Service is based on (1) their existing business relationship with affiliates of Strategic, including FBS and NFS, and (2) the Advisor’s agreement to comply with the participation criteria for the Service (as disclosed in Strategic’s Form ADV Part 2A Brochure for the Service). The presentation of the Advisors for your consideration is based on a comparison of personal information that you have provided and the profile information that each of the Advisors have provided to Strategic. The names of the Advisors come from a pre-determined list compiled by Strategic from a pool of investment advisors that meet certain objective eligibility criteria and who conduct brokerage activities on behalf of their customers through Strategic’s affiliates, FBS and NFS. In no event shall Strategic's providing the names of the Advisors constitute an endorsement, recommendation or opinion as to the quality of an 3. Based on the information provided by you and the participating Advisors in the Service, Strategic will use an automated screening tool to generate a list of all Advisors that align with your screening criteria, and will inform you of the total number of such Advisors in the Service. You will be asked to sort the list of Advisors based on your preference for certain advisory services, and the screening tool will provide a list of Advisors based on each Advisor’s disclosed percentage of assets under management in a certain discipline or the percentage of current clients for which the Advisor provides a certain service. This ranking is based solely on the percentages disclosed by the Advisor, and Strategic does not verify these percentages and makes no representation that any Advisor that passes the screening criteria offers additional expertise or experience in a given advisory service. You may choose to use up to three different categories of advisory services to sort Advisors; in such cases, our advisor screening tool will equally weight each of the criteria selected to arrive at a list of Advisors for your consideration. Strategic will then provide you with an initial list of two Advisors for your consideration. You may search for Advisors using up to two discrete sets of screening criteria in any one 24 hour period, and Strategic will provide you with up to four Advisors for your

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SFIDELITY WEALTH ADVISOR SOLUTION ®

REFERRAL AGREEMENT AND

ACKNOWLEDGMENT

Please keep a copy of this Referral Agreement and Acknowledgement (the “Agreement”) for your records. Fidelity Wealth Advisor Solutions (“WAS” or the “Service”) is a referral service of Strategic Advisers LLC (“Strategic” and, together with its affiliates, “Fidelity Investments”), a registered investment adviser and Fidelity Investments company. The Service is designed for current and prospective clients of Fidelity Investments and other investors who seek to receive referrals to third party independent investment advisory firms (each an “Advisor”). As part of these referrals, Strategic is required to provide you with certain information regarding WAS and your Advisor is required to obtain your acknowledgement of your receipt of this information.

By signing this Agreement, you hereby acknowledge and agree that:

1. Neither Strategic nor any other Fidelity Investments company is affiliated in any way with the Advisors that participate in the Service, and no Advisor has authority to act for or obligate Strategic

Advisor's investment products or services or investment performance, or the appropriateness of any particular advisory service for your particular circumstances.

or its affiliates or to make any representations on their behalf. Advisors are customers of affiliates of Strategic, including Fidelity Brokerage Services LLC (“FBS”) and National Financial Services LLC (“NFS”), and such affiliates receive compensation from Advisors’ customers for the clearing, custody and other brokerage services associated with any accounts held with such affiliates.

2. Each Advisor’s inclusion in the Service is based on (1) their existing business relationship with affiliates of Strategic, including FBS and NFS, and (2) the Advisor’s agreement to comply with the participation criteria for the Service (as disclosed in Strategic’s Form ADV Part 2A Brochure for the Service). The presentation of the Advisors for your consideration is based on a comparison of personal information that you have provided and the profile information that each of the Advisors have provided to Strategic. The names of the Advisors come from a pre-determined list compiled by Strategic from a pool of investment advisors that meet certain objective eligibility criteria and who conduct brokerage activities on behalf of their customers through Strategic’s affiliates, FBS and NFS. In no event shall Strategic's providing the names of the Advisors constitute an endorsement, recommendation or opinion as to the quality of an

3. Based on the information provided by you and the participating Advisors in the Service, Strategic will use an automated screening tool to generate a list of all Advisors that align with your screening criteria, and will inform you of the total number of such Advisors in the Service. You will be asked to sort the list of Advisors based on your preference for certain advisory services, and the screening tool will provide a list of Advisors based on each Advisor’s disclosed percentage of assets under management in a certain discipline or the percentage of current clients for which the Advisor provides a certain service. This ranking is based solely on the percentages disclosed by the Advisor, and Strategic does not verify these percentages and makes no representation that any Advisor that passes the screening criteria offers additional expertise or experience in a given advisory service. You may choose to use up to three different categories of advisory services to sort Advisors; in such cases, our advisor screening tool will equally weight each of the criteria selected to arrive at a list of Advisors for your consideration. Strategic will then provide you with an initial list of two Advisors for your consideration. You may search for Advisors using up to two discrete sets of screening criteria in any one 24 hour period, and Strategic will provide you with up to four Advisors for your

 

consideration with respect to any single set of screening criteria in any one 24 hour period. This Agreement will remain in effect for a period of 90 days from the date of this Agreement, and Strategic w i l l provide you with a maximum of ten Advisors for your consideration in response to any single set of screening criteria over the course of the 90 day period. Strategic shall be under no obligation to affirmatively update the list of Advisors provided to you, or update the information pertaining to any Advisor during the 90 day period, unless you specifically request.

4. There may be other investment advisers

that do not participate in WAS that are equally or more appropriate for your specific circumstances. You are under no obligation to contact or to hire any Advisor you learn about through the Service, or to give an Advisor trading discretion over your accounts. However, if you request, Strategic will provide your name and contact information to the referred Advisors for the purpose of setting up an initial meeting with you. As a result, the services provided to you by Strategic through WAS may include, upon receipt of this signed Agreement, the sharing of your personal information with referred Advisors that participate in the Service, and you consent to any such sharing of information.

5. You must conduct your own interviews and evaluation of any Advisor that you may consider hiring to satisfy yourself that the Advisor, and any advisory services they might provide, are right for you. The decision as to which Advisor, if any, to hire is your own.

6. You will not seek to hold Strategic or its affiliates responsible for your decision to hire any Advisor or for any actions an Advisor may take on your behalf with respect to your account(s), regardless of whether such accounts are brokerage accounts maintained with FBS and/or custodied at NFS, or are otherwise held at Fidelity Investments.

7. Strategic has relied on information and representations of each Advisor in determining the Advisors' eligibility to participate in WAS and their ability to match your screening criteria, and Strategic cannot guarantee the a c c u r a c y , completeness or timeliness of information provided by Advisors to Strategic or to you.

8. The services provided to you by Strategic through WAS do not constitute investment advice with respect to a particular investment product, strategy or service including, but not limited to, circumstances where a Strategic representative attends an introductory meeting with you and a prospective Advisor. If you decide to hire an Advisor, Strategic and its affiliates will not undertake to evaluate whether any investment advice provided to you by the Advisor is appropriate for you. Once you have hired an Advisor to manage your assets and/or to provide you with financial planning services, it is your responsibility to monitor your selected Advisor, including the Advisor’s management of your assets, Advisor’s deduction of advisory fees from your account(s), and the Advisor’s performance. Strategic has no discretionary authority or control with respect to the assets under management at any Advisor, and Strategic has no ongoing duty to you with respect to such assets. Strategic will play no role in monitoring or evaluating any advisory services that you may receive from any Advisor, and Strategic has no duty to update you regarding the status of any Advisor in the Service once you receive your referral.

9. If you decide to give an Advisor trading discretion over your account(s) at Fidelity Investments, affiliates of Strategic, including FBS and NFS, may act on the trading instructions received from the Advisor and will not review the trading to evaluate whether the trading is consistent with the Advisor's investment strategy or is otherwise appropriate or suitable for you.

 

You must monitor your account carefully and direct any questions about your investment strategy, portfolio performance or account activity to the relevant Advisor.

10. Based on your stated preferences and needs, Strategic may refer you to Advisors that offer either wealth planning, financial planning or investment management services. While Strategic has evaluated the Advisors based upon the participation criteria for the Service as noted above, Strategic has not made an independent evaluation of any particular product or service, including financial planning or wealth planning services, that is offered by the Advisors. Strategic will not seek to ascertain whether your stated preferences for any investment strategy or product are appropriate for your needs.

11. You will not be charged any fees by Strategic for any referrals made pursuant to this Agreement, or the materials or assistance provided by Strategic as part of the Service. However, Advisors compensate Strategic for referrals according to the fee structure outlined in Section 12 below and in the solicitation disclosure documents applicable to each Advisor. You will receive both a solicitation disclosure document for each Advisor as part of your referral, and a copy of each Advisor’s Form ADV 2A Brochure, and you acknowledge receipt of these documents by executing this agreement. Pursuant to agreements with Strategic, each Advisor has agreed that it will not charge advisory fees in excess of its normal range of advisory fees as a result of the fees it must pay to Strategic as part of this referral.

12. Each Advisor and Strategic have entered into an agreement pursuant to which the Advisor compensates Strategic for referring you to the Advisor if you enter into an investment advisory contract with that Advisor. Specifically, the Advisor will pay Strategic solicitation fees based on the

amount of assets you place under management with the Advisor. From the date you fund an account over which your Advisor has management responsibility, your Advisor has agreed to pay Strategic an annual fee with respect to assets that are held in brokerage accounts maintained with FBS and custodied at NFS equal to the sum of (a) an annual percentage of 0.10% of any and all assets in your (and any household member's) account(s) where such assets are classified by Fidelity Investments as fixed income assets, and (b) an annual percentage of 0.25% of all other assets held in your (and any household member's) account(s) (or such other amounts as disclosed in the solicitation disclosure documents you receive with respect to such Advisor). Your Advisor has agreed to pay Strategic a minimum of either (1) $10,000 per calendar year for participation in the Service ("Minimum Participation Fee") or (2) the aggregate of all account-based solicitation fees that would be payable to Strategic during the calendar year, whichever is greater. Strategic is entitled to its referral fees whether or not you pay your management or advisory fees to your Advisor in accordance with your agreement with such Advisor. In addition, your Advisor has agreed to pay Strategic a one-time of 0.75% based on the assets held in your account(s) if you transfer custody of such assets to a financial institution not affiliated with Strategic. This fee may incentivize your Advisor to encourage you to hold your assets under management in custody with Strategic's affiliates.

13. If the referral agreement entered into between your Advisor and Strategic is terminated, the Minimum Participation Fee described above will no longer apply. However, your Advisor will continue to pay to Strategic all other referral fees described above, calculated based on your (and any household member’s) assets that continue to receive advisory services from such Advisor.

 

14. In limited circumstances, Strategic may waive or reduce fees paid by the Advisor. Strategic may waive or reduce these fees at its discretion based on, among other things, the size of accounts managed by Advisor and other business considerations between Fidelity Investments and the Advisor. Consequently, in order to obtain fee waivers or reductions from Strategic, an Advisor may have an incentive to recommend that your household assets under management by the Advisor be held in accounts at Fidelity Investments.

15. You have received, carefully read and evaluated the following documents: (i) this Agreement, and (ii) Strategic’s Form ADV 2A Brochure for the Service. You understand the terms of the preceding documents and have been given the opportunity to ask questions and receive answers regarding the information contained within each document. You agree to be subject to the terms of the preceding documents. You also acknowledge that you will receive at the time of referral (i) a solicitation disclosure document for each Advisor, and (ii) a Form ADV 2A Brochure for each Advisor. You agree that your referral is not complete until you have received these documents, and you acknowledge that you will review these documents carefully before making a decision to contact any Advisor about their advisory services.

16. Any Advisor to whom you are referred

by the Service is either (i) a registered investment adviser under the Investment Advisers Act of 1940, as amended (“Advisers Act”), or (ii) is a financial institution not required to register with the U.S. Securities and Exchange Commission (“SEC”), operating pursuant to an exemption from federal registration.

17. You acknowledge that Representatives of Strategic may have a financial incentive for you to receive a referral and hire an Advisor instead of choosing other investment options for your assets.

18. Your Advisor may have an incentive to encourage you to hold your assets under management in accounts at Fidelity Investments rather than at another financial institution, which is likely to result in FBS and/or NFS receiving compensation, including brokerage commissions, for clearing, custody or other brokerage services provided for such account(s). Fees received by FBS or NFS for services performed for your accounts are separate from the fees paid by your Advisor to Strategic for participation in WAS.

19. You understand the Solicitation Fees

paid by your Advisor are paid directly to Strategic by the Advisor and that those fees are (i) separate from any advisory fees you may pay to any Advisor, (ii) separate from any fees you may pay to Strategic for investment management or other services, (iii) separate from any clearing, custody and other fees for brokerage services you may pay to FBS with respect to your accounts maintained with FBS and custodied at NFS, and (iv) separate from any other fees for products or services you may pay to any other Fidelity Investments company.

20. This Agreement will be governed by

the internal laws of the Commonwealth of Massachusetts, but nothing in this Agreement will be construed contrary to the Advisers Act or any rule or order of the SEC under the Advisers Act or, where applicable, the provisions of the Employee Retirement Income Security Act of 1974, as amended.

 

Agreed and Acknowledged,

X Signature Date Print Name

X Signature Date Print Name

629286.9.1

For Office Use Only 

Account Number:     Or Prospect ID#:      

Fidelity Wealth Advisor Solutions®

Program Fundamentals

Strategic Advisers LLC

245 Summer Street, V5D

Boston, MA 02210

800-544-3455

March 29, 2018

This brochure was developed for those who are considering a referral from the Fidelity Wealth Advisor Solutions® program. It provides information about the qualifications and business practices of Strategic Advisers LLC (“Strategic Advisers”), a Fidelity Investments company, as well as information about the Fidelity Wealth Advisor Solutions program.

Throughout this brochure and related materials, Strategic Advisers may refer to itself as a “registered investment adviser” or “being registered.” These statements do not in any way imply a certain level of skill or training.

If you have any questions about the contents of this brochure, please contact us at 800-544-3455. The information in this brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority.

Additional information about Strategic Advisers is available on the SEC’s website at www.adviserinfo.sec.gov.

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S U M M A R Y O F M AT E R I A L C H A N G E S

The SEC requires investment advisers to provide and deliver an annual summary of material changes to their advisory services program brochure (also referred to as the Form ADV Part 2A). The section below highlights only material revisions that have been made to the Fidelity Wealth Advisor Solutions Program Brochure from March 31, 2017, through March 29, 2018.

IMPORTANT INFORMATION ABOUT STRATEGIC ADVISERS

Strategic Advisers, Inc., has transitioned from a corporation to a limited liability company. All references to Strategic Advisers, Inc., are deemed to refer to Strategic Advisers LLC. Client Agreements entered into with Strategic Advisers, Inc., shall continue in full force and effect as if entered into with Strategic Advisers LLC.

IMPORTANT INFORMATION ABOUT CHANGES TO YOUR ADVISORY SERVICE

Strategic Advisers LLC will provide this investment advisory program until July 16, 2018. At that time, Fidelity Personal and Workplace Advisors LLC (“FPWA”) will become the sponsor of this program. Agreements with participating Advisors as defined herein will be transferred to FPWA.

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TA B L E O F C O N T E N T S

SUMMARY OF MATERIAL CHANGES 2

ADVISORY BUSINESS 4

FEES AND COMPENSATION 6

PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT 8

TYPES OF CLIENTS 8

METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS 8

DISCIPLINARY INFORMATION 9

OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 9

CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING 13

BROKERAGE PRACTICES 14

REVIEW OF ACCOUNTS 14

CLIENT REFERRALS AND OTHER COMPENSATION 14

CUSTODY 14

INVESTMENT DISCRETION 14

VOTING CLIENT SECURITIES 14

FINANCIAL INFORMATION 14

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A D V I S O R Y B U S I N E S S

Strategic Advisers LLC (“Strategic,” “Strategic Advisers,” or sometimes referred to as “we” or “us” in this document), is a registered investment adviser and an indirect wholly owned subsidiary of FMR LLC (collectively with Strategic and its affiliates, “Fidelity Investments” or “Fidelity”). Strategic was incorporated in 1977 and provides the referral services for the Fidelity Wealth Advisor Solutions® program (herein, the “Service” or “WAS”).

As of December 29, 2017, Strategic Advisers’ total assets under management were $324,851,600,000 on a discretionary basis, and $15,556,800,000 on a nondiscretionary basis.

THE FIDELITY WEALTH ADVISOR SOLUTIONS PROGRAM

WAS is a referral service designed for existing and prospective clients of Fidelity who seek to receive referrals to third-party independent investment advisory firms (each, an “Advisor” and together “Advisors”) that may help you meet your asset management, wealth management, and financial planning needs. Based on the information you provide to us as part of the profiling process, we will identify two or more Advisors for you to consider. The WAS referral service is complete upon our delivery of information regarding identified Advisors and it is solely your responsibility to determine whether to meet with and/or retain an Advisor. If requested, we can run additional analysis to provide you with information about additional Advisors that align with your screening criteria within 90 days of your initial request for information regarding any Advisor.

We will provide you with documentation and information about each Advisor that is identified for a referral. This documentation and information has been provided to us by each Advisor and we have not reviewed or verified the accuracy of such documentation or information. It is important that you understand that you have no obligation to contact or retain the services of any Advisor you learn about through the Service. You should interview and evaluate each Advisor you may consider hiring to ensure that the Advisor, and the advisory services each Advisor may provide, are right for you. Each Advisor may have its own account minimums and client restrictions.

Advisors are identified from among a universe of registered investment advisers that (i) have a business relationship with affiliates of Strategic, including Fidelity Brokerage Services LLC (“FBS”) and National Financial Services LLC (“NFS”) and (ii) agree to comply with the participation criteria for the Service (as described below). Advisors are not affiliated with or agents of Fidelity, and Advisors pay a fee to Strategic for referrals (as explained in more detail in the section below titled “Fees and Compensation”). Certain affiliates of Strategic, namely FBS and NFS, receive compensation from the Advisors and/or the Advisors’ clients for the clearing, custody, and other brokerage services associated with any accounts held with Strategic’s affiliates.

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THE REFERRAL PROCESS

A Fidelity representative will work with you to gather certain information including, but not limited to, your investing preferences, geographic preferences, the amount you anticipate investing with an Advisor, and the types of strategies and services you want to receive. To arrive at a list of Advisors that align with your screening criteria, the Fidelity representative will use our automated screening tool to compare the profile information you have provided to the Fidelity representative with the information provided by the Advisors. It is important for you to understand that we have not verified the information and documentation provided by the Advisors, and we do not make any representation that any Advisor that aligns with your screening criteria offers certain expertise or experience in a given advisory service.

Along with the names of the referred Advisors, you will receive (i) a firm profile for each Advisor, which includes a summary of relevant information provided to us by the Advisor, (ii) a solicitation disclosure document for each Advisor, which includes legally required information about the Advisor and the Advisor’s relationship with Strategic, and (iii) a copy of each Advisor’s Form ADV Part 2A for their advisory services (their “Brochure”). You should review all these documents carefully before making any decisions to contact any Advisor. If you decide to participate in the Service, you will be required to execute our Referral Agreement and Acknowledgment Agreement to confirm that you received and reviewed these important documents. In addition, upon your request and with your authorization, we can provide certain information about you to referred Advisors to help facilitate your initial meeting.

The Service is designed to provide you with Advisors for your consideration that may meet your investment and financial planning needs; however, the Service does not otherwise constitute a recommendation by Strategic with respect to any Advisor referred by the Service. Strategic does not provide investment advice or recommendations to buy or sell securities or other property in connection with the Service.

The referral pursuant to the Service is complete upon our delivery of information regarding identified Advisors and it is solely your responsibility to determine whether to meet with and/or retain an Advisor. If requested, we can run additional analysis to provide you with information about Advisors that align with your screening criteria within 90 days of your initial request for information regarding an Advisor. We will not provide you with ongoing information regarding an Advisor, including whether such Advisor continues to participate in the Service.

YOUR RESPONSIBILITY

The decision as to which Advisor, if any, to hire is your own. If you decide to hire an Advisor, it is your responsibility to work with your Advisor to determine if the services it provides are appropriate for you. If you decide to give an Advisor trading discretion or other authority over your Fidelity account(s) and the Advisor directs transactions to affiliates of Strategic, Strategic’s affiliates will act on the instructions received from the Advisor and will not review or evaluate the Advisor’s trading activity to determine if such trading is consistent with the Advisor’s investment strategies or is otherwise appropriate or suitable for you. We have no authority or control with respect to the assets under management at any Advisor, and we have no ongoing duty to you with respect to the Advisor’s management of such assets.

It is also your responsibility to monitor your selected Advisor, including the Advisor’s management of your assets and the Advisor’s performance. All questions about your investment strategy, portfolio performance, and the Advisor’s activity should be directed to your selected Advisor. We will play no role in monitoring or evaluating any advisory services that you may receive from any Advisor you choose to work with, and we have no duty to update you regarding any referred Advisor once you receive your referral, including whether such Advisor continues to participate in the Service.

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F E E S A N D C O M P E N S AT I O N

FEES PAID TO STRATEGIC FOR YOUR REFERRAL

You do not directly pay any fee for the Service. If you decide to hire an Advisor referred by the Service, you will pay fees to that Advisor based on the services it provides to you and the terms and conditions of any investment management and advisory agreements between you and the Advisor. Fees will vary from Advisor to Advisor and will be disclosed in the Advisor’s brochure. We are not acting as an investment manager within the meaning of the Employee Retirement Income Security Act of 1974, as amended and including underlying regulations of the Internal Revenue Code, with respect to your account as a result of the Service.

As described herein, Advisors pay solicitation fees to Strategic for each client referral pursuant to the agreement between Strategic and each Advisor (“Solicitation Agreement”). The Solicitation Agreement provides that each Advisor will pay to Strategic a solicitation fee based on the value of a referred client’s accounts opened or maintained with FBS, and custodied at NFS, that are managed or advised pursuant to an investment advisory agreement between that Advisor and a client or that client’s household members, which includes persons/entities sharing the same residence address as the Advisor’s client (collectively, “Client Accounts”). The Solicitation Agreement between Strategic and each Advisor states that the Advisor will not change its clients advisory fees in excess of its normal range of advisory fees as a result of the solicitation fees it must pay to Strategic pursuant to the WAS referral program.

Specifically, Advisors have agreed to pay Strategic an amount equal to the sum of (i) an annual percentage of 0.10% of “Fixed Income and cash equivalent assets” (as defined by internal FBS systems) held in Client Accounts and (ii) an annual percentage of 0.25% of all other assets held in Client Accounts.

The minimum annual solicitation fee payable to Strategic by any Advisor is $10,000 (the “Minimum Solicitation Fee”). In the event that an Advisor or Strategic terminates the Solicitation Agreement prior to the end of a full calendar year, the Minimum Solicitation Fee is prorated based on the number of completed quarters in which the Solicitation Agreement was in effect for such year. In addition, each Advisor has agreed to pay Strategic a one-time fee of 0.75% (the “Non-Fidelity Custody Fee”) if an Advisor’s client transfers custody of the assets held in Client Accounts to a financial institution not affiliated with Strategic. The Non-Fidelity Custody Fee will be assessed based on the assets held in Client Accounts as of the date the client transfers custody to another financial institution.

As a result of an Advisor’s participation in the Service, it is likely that the Advisor will use affiliates of Strategic, namely FBS and NFS, to effect securities transactions for Client Accounts, which will generate brokerage commissions and other revenues for affiliates of Strategic, including FBS and NFS. The Non-Fidelity Custody Fee may also incentivize an Advisor to encourage you, as the Advisor’s client, to hold your assets under management in custody with Strategic’s affiliate rather than another financial institution, which is likely to result in Strategic’s affiliates, including FBS and NFS, receiving compensation for securities transactions affected for Client Accounts. In general, you may direct the Advisor to use any brokerage firm you choose to support your trading activity.

If you terminate your advisory agreement with an Advisor, the Advisor shall have no ongoing obligation to pay Strategic solicitation fees with respect to your Client Accounts. However, your Advisor’s obligation to pay solicitation fees for Client Accounts remains in effect even if Strategic and the Advisor terminate the Advisor’s participation in the Service.

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Under certain circumstances, Strategic may waive or reduce the solicitation fees payable to Strategic by an Advisor. Agreements, including the Solicitation Agreement, between Strategic and each Advisor are subject to change.

The compensation received by Strategic and its affiliates from Advisors, both from within and outside the Service, creates a potential conflict of interest both when we select Advisors to participate in the Service and when we refer you to those Advisors. Strategic addresses these conflicts in several ways, including (i) establishing participation criteria described above and securing Advisors’ agreement to adhere to those criteria before admission into the Service and on a periodic basis thereafter, (ii) establishing an oversight team within Strategic to review participation in the Service by Advisors, (iii) excluding the revenue received by Strategic and its affiliates from consideration in the screening criteria used by the tool to align Advisors with clients, and (iv) periodically evaluating and overseeing the referral process for compliance with the policies and procedures governing the Service.

The solicitation fees paid by your Advisor are paid directly to Strategic by the Advisor. The solicitation fees are separate from (i) any advisory fees you may pay to an Advisor, (ii) any fees you may pay to Strategic for investment management services, (iii) any fees paid to Strategic’s affiliates, including FBS and NFS for brokerage services, and (iv) any other fees for products or services you may pay to any other Fidelity Investments company.

INFORMATION ABOUT REPRESENTATIVE COMPENSATION

Fidelity representatives who make referrals may receive compensation as a result of making such referrals. In particular, certain representatives who make referrals may receive 0.10% of referred assets upon the completion of a successful referral where a client transfers assets to a referred Advisor, along with additional compensation based on the amount of assets clients consolidate with Fidelity, including assets referred to Advisors in the Service. In many cases, this compensation is greater than what the representative would receive if you participated in other programs or purchased other investment products. In addition, Fidelity representatives who make referrals under the Service may participate in sales contests and may earn additional rewards based on sales criteria, including the number and asset value of referrals made. Therefore, Fidelity representatives who make referrals as part of the Service may have a financial incentive to present referrals and for you to hire an Advisor, and because of those incentives they may suggest that you consider hiring an Advisor pursuant to the Services instead of choosing other programs or services. However, each representative’s incentive payment is subject to manager evaluation and modification to ensure adherence to Fidelity’s policies and procedures with respect to referring clients to appropriate products and services. For additional information about how Fidelity Investments compensates its representatives in connection with the Service and other products, please see the “Introduction to Representatives’ Compensation” disclosure document (available on Fidelity.com), or contact a Fidelity representative.

It is important to note that in determining a Fidelity representative’s compensation, Fidelity considers whether the Fidelity representative provides guidance about appropriate products and services based on customer needs. We take this approach to client relationships very seriously, and review representative interactions in order to help ensure this standard is met.

ADDITIONAL FEE INFORMATION

Affiliates of Strategic receive additional compensation for the Advisors’ clients for the clearing, custody, and other brokerage services associated with the Advisors’ client accounts maintained with

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FBS and/or NFS. As a result of an Advisor’s participation in the Service, it is likely that the Advisor will use affiliates of Strategic to effect securities transactions for your account(s) held at Fidelity, which will generate brokerage commissions and other revenues for affiliates of Strategic, including FBS and NFS. In general, you may direct the Advisor to use any brokerage firm you choose to support your trading activity.

P E R F O R M A N C E - B A S E D F E E S A N D S I D E - B Y- S I D E M A N A G E M E N T

Strategic Advisers does not charge advisory fees, including performance-based advisory fees, under the Service. Strategic provides only referrals to unaffiliated third-party investment advisers under the Service, and is not responsible for discretionary management of accounts or assets through the Service. Therefore, Strategic Advisers has no opportunity to engage in side-by-side trading.

T Y P E S O F C L I E N T S

The Service is generally available to current and prospective clients of Strategic and its affiliates, including FBS, who inquire about receiving asset management, wealth management, or financial planning services from Advisors.

In order to participate in the Service, you must be a U.S. person (including a U.S. resident alien), reside in the U.S., have a valid U.S. permanent mailing address, and have a valid U.S. taxpayer identification number. We reserve the right to terminate your Service (or limit your rights to access any or all account features, products, or services) for any reason. The Service is not available to foreign investors, non-U.S. trusts, and government entities as defined by the SEC’s pay-to-play rule according to Rule 206(4)-5 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) — these include federal, state, or local governments, boards, commissions, public schools, colleges, universities, hospitals, health care organizations, and public entity retirement plans such as Internal Revenue Code sections 403(b), 401(a), or 457 plans.

M E T H O D S O F A N A LY S I S , I N V E S T M E N T S T R AT E G I E S , A N D R I S K O F L O S S

Through the use of our automated screening tool, we seek to refer current and prospective clients to Advisors based on a comparison of the information you share with us about your asset management, wealth management, and financial planning needs, with the information Advisors have provided to us about their firms and the type of advisory services they provide to their clients. In no event shall Strategic’s providing documentation and/or information about any of the Advisors constitute an endorsement, recommendation, or opinion as to the quality of an Advisor’s investment products, services, or investment performance.

We have relied on the information and representations of each Advisor as part of the Advisor’s eligibility to participate in the Service and to align the Advisor with your stated needs and preferences for the referral. All investment strategies employed by the Advisors that participate in the Service are subject to certain risks, including the risk of loss. Please see the Advisor’s Brochure for additional information about risks associated with an Advisor’s investment strategies.

Advisors that participate in the Service are limited to unaffiliated third-party registered investment advisers that have business relationships with affiliates of Strategic, namely FBS and NFS. There may

9

be other investment advisers, apart from those we may make available to you through the Service, that are equally or more appropriate for your specific circumstances.

We use the following objective factors, among other factors, to determine which Advisors are eligible to participate in the Service:

1. Federal Registration. A participating Advisor must be an investment adviser registered and in good standing with the SEC and/or any applicable state securities regulatory authorities or an entity that is exempt from registration as an investment adviser pursuant to Section 202(a)(11)(A) under the Advisers Act.

2. Representative Registration. Representatives of a participating Advisor who meet the definition of “Investment Adviser Representative” under Rule 203A-3 under the Advisers Act and who provide services to you must be registered/licensed appropriately in the required jurisdictions.

3. Fee-Based Compensation. Participating Advisors must charge fee-based, asset-based, or flat-rate investment advisory service fees (which may include hourly fees).

4. Assets Under Management. Participating Advisors must maintain a minimum of $350 million in total regulatory assets under management, as reported in response to Item 5 in Part 1A of the Advisor’s Form ADV, throughout the duration of the Advisor’s participation in the Service.

5. Errors and Omissions Liability. Participating Advisors and all associated persons of the Advisor who manage client assets or who supervise such associated persons must at all times be covered through both Errors and Omissions Liability Insurance and Fidelity Bond Coverage, with a minimum of $2 million Errors and Omissions Liability Insurance and $1 million Fidelity Bond Coverage.

6. Principals and Employees. Participating Advisors must maintain a minimum of two principals or officers as well as a minimum of five employees.

We may, in our sole discretion, waive these criteria in whole or in part with respect to any Advisor at any time, and we reserve the right to suspend referrals to any Advisor or terminate an Advisor’s participation in the Service for any reason. While we have evaluated the referred Advisors based on the participation criteria for the Service, as noted above, we have not made an independent evaluation of any particular product or service, including financial planning or wealth planning services, that is offered by any Advisor, and we will not refer you to any particular product or strategy offered by any Advisor.

D I S C I P L I N A R Y I N F O R M AT I O N

Strategic has no material disclosable legal or disciplinary events for its management persons associated with its advisory services.

O T H E R F I N A N C I A L I N D U S T R Y A C T I V I T I E S A N D A F F I L I AT I O N S

Strategic is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is wholly owned by FMR LLC. FMR LLC is a Delaware limited liability company that, together with its affiliates and subsidiaries, is generally known to the public as Fidelity Investments or Fidelity. Various direct or indirect subsidiaries of FMR LLC are engaged in investment advisory, brokerage, banking, or insurance businesses. From time to time, Strategic and our clients may have material business relationships with any of the subsidiaries and affiliates of FMR LLC. In addition, the principal officers of Strategic serve as officers and/or employees of affiliated companies that are engaged in various aspects of the financial services industry.

10

Strategic Advisers is not registered as a broker-dealer, futures commission merchant, commodity pool operator, or commodity trading advisor, nor does it have an application pending to register as such. Certain management persons of Strategic Advisers are registered representatives of FBS, and/or Fidelity Investments Institutional Services Company, Inc. (“FIISC”), Strategic Advisers affiliates and registered broker-dealers; however, such management persons are not involved in the management, operations, or day-to-day oversight of the program outlined in this brochure.

From time to time, we or our clients may have a material business relationship with the following affiliated companies:

INVESTMENT COMPANIES AND INVESTMENT ADVISERS

Fidelity Personal and Workplace Advisors LLC (“FPWA”) is a wholly owned subsidiary of Fidelity Advisory Holdings LLC, which in turn is wholly owned by FMR LLC, and a registered investment adviser under the Advisers Act. FPWA provides nondiscretionary investment management services and, effective July 16, 2018, will serve as the sponsor to investment advisory programs, including the Service.

Fidelity Management & Research Company (“FMRCo”) is a wholly owned subsidiary of FMR LLC, and is a registered investment adviser under the Advisers Act. FMRCo principally provides portfolio management services as an adviser or a sub-adviser to registered investment companies. FMRCo may also provide portfolio management services as an adviser or sub-adviser to clients of other affiliated and unaffiliated advisers.

Fidelity Investments Money Management, Inc. (“FIMM”), is a wholly owned subsidiary of FMR LLC and a registered investment adviser under the Advisers Act. FIMM provides portfolio management services as a sub-adviser to certain clients, including investment companies in the Fidelity Group of funds or as an adviser. In addition, it is expected that we may share employees from time to time with FIMM.

FMR Co., Inc. (“FMRC”), is a wholly owned subsidiary of FMRCo and is a registered investment adviser under the Advisers Act. FMRC may provide portfolio management services as a sub-adviser to certain of Strategic Advisers’ customers. FMRC may also provide portfolio management services as an adviser or a sub-adviser to customers of other affiliated and unaffiliated advisers.

FIAM LLC (“FIAM”) is a wholly owned subsidiary of FIAM Holdings Corp., which in turn is wholly owned by FMR LLC, and provides investment management services, including sub-advisory services to Strategic Advisers, or its affiliates. FIAM is a registered investment adviser under the Advisers Act. FIAM is also registered with the Central Bank of Ireland.

BROKER-DEALERS

Fidelity Distributors Corporation (“FDC”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., acts as principal underwriter and general distribution agent of the registered investment companies advised by FMRCo. FDC is a registered broker-dealer under the Securities Exchange Act of 1934 (“Exchange Act”).

National Financial Services LLC (“NFS”) is engaged in the institutional brokerage business and provides clearing and execution services for other brokers. NFS is a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC. Fidelity Global Brokerage Group, Inc., is a holding company that provides administrative services to NFS. Fidelity Capital Markets (“FCM”), a division of NFS, may execute transactions for our investment company and other clients. Additionally, FCM operates CrossStream®, an alternative trading system

11

that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. FCM charges a commission to both sides of each trade executed in CrossStream. Using CrossStream, FCM crosses trades for client accounts, and it charges a commission on its trades to both of its brokerage customers. CrossStream may be used to execute transactions for our investment company and other clients. NFS is a registered broker-dealer under the Exchange Act, and NFS is also registered as an investment adviser under the Advisers Act. NFS may serve as a clearing agent for client transactions that we place with certain broker-dealers. NFS may provide transfer agent or subtransfer agent services to certain of our or our affiliates’ clients. NFS provides transaction processing services in conjunction with the implementation of our discretionary investment management instructions. NFS also provides custodial, recordkeeping, and reporting services to clients. FPTC compensates NFS for these services.

In all cases, transactions executed by affiliated brokers on behalf of investment company clients are effected in accordance with Rule 17e-1 under the Investment Company Act of 1940 and procedures approved by the Boards of Trustees of the funds. The Board of Trustees of each fund in the Fidelity group of funds has approved FCM effecting fund portfolio transactions and retaining compensation in connection with such transactions pursuant to Section 11(a) of the Exchange Act.

Luminex Trading & Analytics LLC (“LTA”), a registered broker-dealer and alternative trading system, operates an electronic execution utility (the “LTA ATS”) that allows orders submitted by its subscribers to be crossed against orders submitted by other subscribers. FMR LLC is the majority owner of LTA. LTA charges a commission to both sides of each trade executed in the LTA ATS. The LTA ATS may be used to execute transactions for Strategic Advisers’ or Strategic Advisers’ affiliates’ investment company and other advisory clients. NFS serves as the clearing agent for transactions executed in the LTA ATS.

Fidelity Brokerage Services LLC (“FBS”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., which in turn is wholly owned by FMR LLC, is a registered broker-dealer under the Exchange Act and provides brokerage products and services, including the sale of shares of investment companies advised by FMRCo to individuals and institutions, including retirement plans administered by affiliates. Pursuant to referral agreements and for compensation, representatives of FBS may refer customers to various services offered by FBS’s related persons, including Strategic Advisers. In addition, along with Fidelity Insurance Agency, Inc. (“FIA”), FBS is the distributor of insurance products, including variable annuities, which are issued by FMRCo’s related persons, Fidelity Investments Life Insurance Company (“FILI”), and Empire Fidelity Investments Life Insurance Company® (“EFILI”). FBS may provide shareholder services to certain FMRCo’s or FMRCo’s affiliates’ clients.

Fidelity Investments Institutional Services Company, Inc. (“FIISC”), a wholly owned subsidiary of Fidelity Global Brokerage Group, Inc., primarily markets Fidelity mutual funds and other products advised by FMRCo or an affiliate thereof to third-party financial intermediaries and certain institutional investors. FIISC is a registered broker-dealer under the Exchange Act.

INSURANCE COMPANIES OR AGENCIES

FILI, a wholly owned subsidiary of FMR LLC, is engaged in the distribution and issuance of life insurance and annuity products that may offer shares of investment companies managed by Strategic Advisers or its affiliates.

EFILI is a wholly owned subsidiary of FILI, which in turn is wholly owned by FMR LLC, and is engaged in the distribution and issuance of life insurance and annuity products that may offer shares of investment companies managed by Strategic Advisers or its affiliates to residents of New York.

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FIA, a wholly owned subsidiary of FMR LLC, is engaged in the business of selling life insurance and annuity products of affiliated and unaffiliated insurance companies.

BANKING INSTITUTIONS

Fidelity Management Trust Company (“FMTC”), a trust company organized and operating under the laws of the Commonwealth of Massachusetts, provides nondiscretionary trustee and custodial services to employee benefit plans and individual retirement accounts through which individuals may invest in mutual funds managed by FMR or its affiliates, and discretionary investment management services to institutional clients. FMTC is a wholly owned subsidiary of FMR LLC.

Fidelity Personal Trust Company, FSB (“FPTC”), a federally chartered savings bank that offers fiduciary services to its customers that include Trustee or Co-Trustee services, custody, income and principal accounting, investment management services, and recordkeeping and administration. FPTC is a wholly owned subsidiary of Fidelity Thrift Holding Company, Inc., which in turn is a wholly owned subsidiary of FMR LLC.

LIMITED PARTNERSHIPS AND LIMITED LIABILITY COMPANY INVESTMENTS

Strategic Advisers may provide discretionary investment management to partnerships and limited liability companies designed to facilitate acquisitions by mutual funds offered by Strategic Advisers. These funds are privately offered consistent with stated investment objectives. Strategic Advisers does not intend to engage in borrowing, lending, purchasing securities on margin, short selling, or trading in commodities in these funds.

PARTICIPATING AFFILIATES

Fidelity Business Services India Private Limited (“FBS India”), with its registered office in Bangalore, is incorporated under the laws of India and is ultimately owned by FMR LLC through certain of its direct or indirect subsidiaries. Certain employees of FBS India (“FBS India Associated Employees”) may from time to time provide certain research services for us, which we may use for our clients.

FBS India is not registered as an investment adviser under the Advisers Act and is deemed to be a “Participating Affiliate” of Strategic Advisers (as this term has been used by the SEC’s Division of Investment Management in various no-action letters granting relief from the Advisers Act’s registration requirement for certain affiliates of registered investment advisers). Strategic Advisers deems FBS India and each of the FBS India Associated Employees as “associated persons” of Strategic Advisers within the meaning of Section 202(a)(17) of the Advisers Act. FBS India Associated Employees and FBS India, through such employees, may contribute to Strategic Advisers’ research process and may have access to information concerning securities that are being selected for the client prior to the effective implementation of such selections. As a Participating Affiliate of Strategic Advisers, FBS India has agreed to submit itself to the jurisdiction of United States courts for actions arising under United States securities laws in connection with investment advisory activities conducted for Strategic Advisers’ customers.

Strategic maintains a list of FBS India Associated Employees whom FBS India has deemed “associated persons,” which Strategic Advisers will make available to its customers upon request.

13

C O D E O F E T H I C S , PA R T I C I PAT I O N O R I N T E R E S T I N C L I E N T T R A N S A C T I O N S , A N D P E R S O N A L T R A D I N G

Strategic has adopted a Code of Ethics for Personal Trading (the “Code of Ethics”). The Code of Ethics applies to all officers, directors, and other supervised persons of Strategic and requires that they place the interests of Strategic’s clients above their own. The Code of Ethics establishes securities transactions requirements for all covered persons, including their spouses. More specifically, the Code of Ethics contains provisions requiring:

(i) Standards of general business conduct reflecting the advisers’ fiduciary obligations,

(ii) Compliance with applicable federal securities laws,

(iii) Employees and their covered persons to move their covered accounts to FBS unless an exception has been granted,

(iv) Reporting and review of personal securities transactions and holdings for persons with access to certain nonpublic information,

(v) Prohibition of purchasing securities in initial public offerings unless an exception has been approved,

(vi) Reporting of Code of Ethics violations, and

(vii) Distribution of the Code of Ethics to all supervised persons, documented through acknowledgments of receipt.

Core features of the Code of Ethics generally apply to all employees of Fidelity Investments. The Code of Ethics also imposes additional restrictions and reporting obligations on certain advisory personnel, research analysts, and portfolio managers, including (i) preclearing of transactions in covered securities, (ii) prohibiting investments in limited offerings without prior approval, (iii) reporting of transactions in covered securities on a quarterly basis, (iv) reporting of accounts and holdings of covered securities on an annual basis, and (v) disgorgement of profits from short-term transactions unless an exception has been approved. Violation of the Code of Ethics requirements may also result in the imposition of remedial action. The Code of Ethics will generally be supplemented by other relevant Fidelity policies, including the Policy on Inside Information, Rules for Broker-Dealer Employees, and other written policies and procedures adopted by Fidelity and Strategic. A copy of the Code of Ethics will be provided upon request.

Strategic Advisers and its related persons may buy or sell for themselves securities that they also recommend to clients. The potential conflicts of interest involved in such activities are contemplated in the Code of Ethics and other relevant Fidelity policies. In particular, the Code of Ethics and other Fidelity policies are designed to ensure that Fidelity personnel never place their personal interests ahead of Fidelity’s clients in an attempt to benefit themselves or another party. The Code of Ethics and other Fidelity policies impose sanctions if these requirements are violated.

From time to time, in connection with our business, supervised persons may obtain material nonpublic information that is usually not available to other investors or the general public. In compliance with applicable laws, Strategic Advisers has adopted a comprehensive set of policies and procedures that prohibit the use of material nonpublic information by personnel. In addition, Fidelity has implemented a policy on Business Entertainment and Workplace Gifts intended to set standards for business entertainment and gifts to help employees make sound decisions with respect to these

14

activities and to ensure that the interests of Strategic Advisers’ clients come first. Similarly, to ensure compliance with applicable “pay to play” rules, Fidelity has adopted a Political Contributions and Activity policy that requires all employees to preclear any political contributions and activities.

B R O K E R A G E P R A C T I C E S

Strategic does not select or recommend broker-dealers for client transactions as part of the Service. However, as described above, an Advisor’s participation in the Service may create incentives for an Advisor to recommend the use of affiliates of Strategic, namely NFS and FBS, for the execution of brokerage transactions and/or the custody of their Client Accounts.

R E V I E W O F A C C O U N T S

Strategic does not conduct an ongoing review of accounts post-referral. Strategic has no discretionary authority or control with respect to the assets under management at any Advisor, and Strategic has no ongoing duty to you with respect to the management of any such assets. Strategic does not monitor or evaluate any advisory services that you may receive from any Advisor you choose to work with, and Strategic has no duty to update you regarding the status of any Advisor in the Service once you receive your referral.

C L I E N T R E F E R R A L S A N D O T H E R C O M P E N S AT I O N

As described herein, Strategic receives compensation from Advisors for referrals made through the Service.

C U S T O D Y

Strategic does not have custody of client securities or accounts with respect to the Service; however, Strategic’s affiliates may have custody of the Advisors’ client accounts. Strategic and its affiliates may have custody of client securities in connection with activities unrelated to the Service.

I N V E S T M E N T D I S C R E T I O N

Strategic does not exercise any investment discretion in connection with referrals made pursuant to the Service.

V O T I N G C L I E N T S E C U R I T I E S

Strategic does not acquire authority or exercise proxy voting on your behalf as part of the Service. You may request a copy of Strategic’s proxy voting guidelines by contacting a Fidelity representative.

F I N A N C I A L I N F O R M AT I O N

Strategic Advisers does not solicit prepayment of client fees.

Strategic Advisers is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients.

The Fidelity Wealth Advisor Solutions® program is provided without charge as a convenience to you by Strategic Advisers LLC, a registered investment adviser and a Fidelity Investments company. Fidelity Wealth Advisor Solutions®, Fidelity, Fidelity Investments, the Fidelity Investments and pyramid design logo, and CrossStream are registered service marks of FMR LLC.Fidelity Brokerage Services LLC, Member NYSE and SIPC, 900 Salem Street, Smithfield, RI 02917© 2018 FMR LLC. All rights reserved.

629286.10.0 1.960529.109

FOR MORE INFORMATION, PLEASE CALL US TOLL FREE AT

8 0 0 - 5 4 4 - 3 4 5 5

Monday through Fr iday, 8 a.m. to 7 p.m. Eastern t ime

Supplemental Brochures for

Fidelity Wealth Advisor Solutions®

Key Fidelity personnel involved with the program include:

• Suzanne Brennan

• Paul Quistberg

Supplemental Brochure:

Fidelity Wealth Advisor Solutions®

Strategic Advisers, Inc.

245 Summer Street,

V5D Boston, MA 02210

617-563-7100

March 31, 2017

On behalf of FMR LLC and its affiliates (“Fidelity”), we thank you for considering a referral from the Fidelity Wealth Advisor Solutions® program (the “Service”).

This supplemental brochure has been developed for existing and prospective clients of Fidelity who seek to receive referrals to third-party independent investment advisory firms that have agreed to participate in the Service. It provides information about Suzanne Brennan, a member of Strategic Advisers, Inc., along with her education and experience, and supplements the Fidelity Wealth Advisor Solutions® program brochure. You should have received a copy of the program brochure. Please contact your Fidelity representative if you did not receive the program brochure or if you have any questions about the contents of this supplement.

Suzanne Brennan

19

Suzanne Brennan

E D U C AT I O N A L B A C K G R O U N D A N D B U S I N E S S E X P E R I E N C E

Suzanne Brennan is chief operating officer for Strategic Advisers, Inc. In conjunction with Paul Quistberg, she is responsible for overseeing advisor due diligence with respect to the program. She also leads a team of more than 60 professionals responsible for the division’s strategic growth and day-to-day operations. Ms. Brennan joined Fidelity in 2006 as vice president of finance for Fidelity Management & Research Company (“FMRCo”), leading a team of analysts responsible for the firm’s financial planning, reporting, and controls. From 2009 to 2011, she was senior vice president for Asset Management Strategy and Planning at FMRCo, where she managed cross-enterprise teams charged with developing, implementing, and measuring industry-changing initiatives and strategic plans.

Born in 1962, Ms. Brennan received her bachelor of science degree from Boston College, with a double major in finance and accounting.

D I S C I P L I N A R Y I N F O R M AT I O N

There are no material disclosable legal or disciplinary events that are material to your evaluation of Ms. Brennan or her integrity.

O T H E R B U S I N E S S A C T I V I T I E S

Ms. Brennan is not actively engaged in any other investment-related business or occupation.

A D D I T I O N A L C O M P E N S AT I O N

Ms. Brennan does not receive any economic benefit or compensation for providing advisory services to any party that is not a client of Strategic Advisers, Inc.

S U P E R V I S I O N

Bruce Herring is president of Strategic Advisers, Inc. Mr. Herring is responsible for ensuring that members of his team involved in the Fidelity Wealth Advisor Solutions® program conduct appropriate due diligence in the selection and ongoing oversight of the Advisors that receive referrals through the Service. This includes, among other things, a review of their investment experience and education, errors and omissions liability insurance coverage, and compliance policies and procedures.

Mr. Herring may be contacted at 617-563-7966.

R E Q U I R E M E N T S F O R S TAT E - R E G I S T E R E D A D V I S E R S

Strategic Advisers, Inc., is not registered with any state securities authority.

Supplemental Brochure:

Fidelity Wealth Advisor Solutions®

Strategic Advisers, Inc.

245 Summer Street,

V5D Boston, MA 02210

617-563-7100

March 31, 2017

On behalf of FMR LLC and its affiliates (“Fidelity”), we thank you for considering a referral from the Fidelity Wealth Advisor Solutions® program (the “Service”).

This supplemental brochure has been developed for existing and prospective clients of Fidelity who seek to receive referrals to third-party independent investment advisory firms that have agreed to participate in the Service. It provides information about Paul Quistberg, a member of Strategic Advisers, Inc., along with his education and experience, and supplements the Fidelity Wealth Advisor Solutions® program brochure. You should have received a copy of the program brochure. Please contact your Fidelity representative if you did not receive the program brochure or if you have any questions about the contents of this supplement.

Paul Quistberg

21

Paul Quistberg

E D U C AT I O N A L B A C K G R O U N D A N D B U S I N E S S E X P E R I E N C E

Paul Quistberg is head of research for Strategic Advisers, Inc. (“SAI”), a registered investment adviser and a Fidelity Investments company. Mr. Quistberg joined the firm in November 2015. In conjunction with Suzanne Brennan, he is responsible for overseeing advisor due diligence with respect to the program. In addition, Mr. Quistberg leads a team of fund analysts responsible for manager selection for SAI.

Born in 1962, Mr. Quistberg has a bachelor of science degree in accounting from the University of Connecticut and a master of business administration degree from the University of Chicago Graduate School of Business. Additionally, he is a Certified Public Accountant (CPA) and a Chartered Financial Analyst (CFA®) charterholder.1

D I S C I P L I N A R Y I N F O R M AT I O N

There are no material disclosable legal or disciplinary events that are material to your evaluation of Mr. Quistberg or his integrity.

O T H E R B U S I N E S S A C T I V I T I E S

Mr. Quistberg is not actively engaged in any other investment-related business or occupation.

A D D I T I O N A L C O M P E N S AT I O N

Mr. Quistberg does not receive any economic benefit or compensation for providing advisory services to any party that is not a client of Strategic Advisers, Inc.

S U P E R V I S I O N

Bruce Herring is president of Strategic Advisers, Inc. Mr. Herring is responsible for ensuring that members of his team involved in the Fidelity Wealth Advisor Solutions® program conduct appropriate due diligence in the selection and ongoing oversight of the Advisors that receive referrals through the Service. This includes, among other things, a review of their investment experience and education, errors and omissions liability insurance coverage, and compliance policies and procedures.

Mr. Herring may be contacted at 617-563-7966.

R E Q U I R E M E N T S F O R S TAT E - R E G I S T E R E D A D V I S E R S

Strategic Advisers, Inc., is not registered with any state securities authority. 1The CFA designation is offered by the CFA Institute. To obtain the CFA charter, candidates must pass three exams demon-strating their competence, integrity, and extensive knowledge in accounting, ethical and professional standards, economics, portfolio management, and security analysis, and must also have at least three years of qualifying work experience, among other requirements.

The Fidelity Wealth Advisor Solutions® program (“the Program”) is provided without charge as a convenience to you by Strategic Advisers, Inc. (SAI), a Fidelity Investments company. In no event shall SAI’s providing the names of one or more regis-tered investment advisers (RIAs) constitute an endorsement, recommendation, or opinion as to the quality or appropriateness of the RIA or the related advisory services. SAI acts as solicitor to the RIAs in the Program, and receives solicitation fees from the RIAs as a result of their participation. RIAs are not affiliated with or agents of SAI or any other Fidelity Investments com-pany, but they are Fidelity Investments customers and their clients compensate Fidelity Investments for custody, clearing, or other brokerage services. You must conduct the evaluation and due diligence you deem necessary to determine whether an RIA and any related advisory services are suitable for your needs. You are under no obligation to contact or engage any RIA. RIAs are eligible to participate in the Program if they represent to Fidelity Investments that they meet the following criteria:(1) RIA is an investment adviser registered and in good standing with the U.S. Securities and Exchange Commission and/or any applicable state securities regulatory authorities or is exempt from such registration;(2) RIA’s representatives who provide services to referred clients are appropriately registered/licensed as “Investment Advisers Representatives” in required jurisdictions;(3) RIA charges fee-based, asset-based, or flat-rate investment advisory service fees (which may include hourly fees);(4) RIA will maintain a minimum of $350,000,000 in total regulatory assets under management, as reported in response to Item 5 in Part 1A of the RIA’s Form ADV, throughout the duration of RIA’s participation in the Program;(5) RIA and all associated persons of the RIA who manage client assets or who supervise such associated persons shall at all times be covered through both Errors and Omissions Liability Insurance and Fidelity Bond Coverage; and(6) RIA maintains a minimum of two principals or officers as well as a minimum of five employees.SAI may, in its sole discretion, waive these criteria in whole or in part with respect to any RIA at any time. Fidelity has relied on the representations of the RIAs in determining whether the criteria have been met, and cannot guarantee the accuracy, completeness, or timeliness of the information provided by the RIAs. RIAs retain the right to accept or reject new advisory accounts. Please see SAI’s Form ADV Part 2A brochure for additional information about the Program.Clearing, custody, or other brokerage services may be provided separately by National Financial Services LLC or Fidelity Brokerage Services LLC, Members NYSE, SIPC. Both are Fidelity Investments companies.The registered trademarks and service marks appearing herein are the property of FMR LLC.Fidelity Brokerage Services LLC, Member NYSE and SIPC, 900 Salem Street, Smithfield, RI 02917© 2017 FMR LLC. All rights reserved.

753229.2.0 1.960529.108

1.963951.105 Rev. 06/2017

FACTS What do Fidelity Investments and the Fidelity Funds do with your personal information?

WHY? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

WHAT? The types of personal information we collect and share depend on the product or service you have with us. This information can include:

Social Security number and employment information assets and income account balances and transaction history

When you are no longer our customer, we continue to share your information as described in this notice.

HOW? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information, the reasons Fidelity Investments and the Fidelity Funds (hereinafter referred to as “Fidelity”) choose to share, and whether you can limit this sharing.

REASONS WE CAN SHARE YOUR PERSONAL INFORMATION

DOES FIDELITY SHARE?

CAN YOU LIMIT THIS SHARING?

For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes No

For our marketing purposes — to offer our products and services to you

Yes No

For joint marketing with other financial companies No We don’t share

For our affiliates’ everyday business purposes — information about your transactions and experiences

Yes No

For our affiliates’ everyday business purposes — information about your creditworthiness

No We don’t share

For nonaffiliates to market to you No We don’t share

QUESTIONS? Call 800-343-3548. If we serve you through an investment professional, please contact them directly. Specific Internet addresses, mailing addresses, and telephone numbers are listed on your statements and other correspondence.

Effective June 2017© 2017 FMR LLC. All rights reserved.

PRIV-INS-0617 524812.35.0

WHO WE ARE

Who is providing this notice? Companies owned by Fidelity Investments using the Fidelity name to provide financial services to customers, and the Fidelity Funds. A list of companies is located at the end of this notice.

WHAT WE DO

How does Fidelity protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Fidelity collect my personal information?

We collect your personal information, for example, when you open an account or direct us to buy/sell your securities provide account information or give us your contact information tell us about your investment portfolio

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only sharing for affiliates’ everyday business purposes — information about your creditworthiness

affiliates from using certain information to market to you sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

DEFINITIONS

Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies. Fidelity Investments affiliates include companies with the Fidelity name (excluding the Fidelity Funds), as listed below, and other financial companies such as National Financial Services LLC, Strategic Advisers, Inc., and FIAM LLC.

Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies. Fidelity does not share with nonaffiliates so they can market to you.

Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Fidelity doesn’t jointly market.

OTHER IMPORTANT INFORMATION

If you transact business through Fidelity Investments life insurance companies, we may validate and obtain information about you from an insurance support organization. The insurance support organization may further share your information with other insurers, as permitted by law. We may share medical information about you to learn if you qualify for coverage, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law. You are entitled to receive, upon written request, a record of any disclosures of your medical record information. Please refer to your statements and other correspondence for mailing addresses.If you establish an account in connection with your employer, your employer may request and receive certain information relevant to the administration of employee accounts.If you interact with Fidelity Investments directly as an individual investor (including joint account holders), we may exchange certain information about you with Fidelity Investments financial services affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowable by law. Information collected from investment professionals’ customers is not shared with Fidelity Investments affiliates for marketing purposes, except with your consent and as allowed by law.The Fidelity Funds have entered into a number of arrangements with Fidelity Investments companies to provide for investment management, distribution, and servicing of the Funds. The Fidelity Funds do not share personal information about you with other entities for any reason, except for everyday business purposes in order to service your account. For additional information, please visit Fidelity.com.

WHO IS PROVIDING THIS NOTICE?

Fidelity Investments companies: Fidelity Brokerage Services LLC; Fidelity Distributors Corporation; Fidelity Investments Institutional Operations Company, Inc.; Fidelity Investments Institutional Services Company, Inc.; Fidelity Management Trust Company; Fidelity Personal Trust Company, FSB; Fidelity Investments Life Insurance Company; Empire Fidelity Investments Life Insurance Company; Fidelity Insurance Agency, Inc.; National Financial Services LLC; Strategic Advisers, Inc.; FIAM LLC. The Fidelity Funds, which include funds advised by Strategic Advisers, Inc.