Tortoise acts as a fiduciary in every client relationship.

Tortoise is a fee–only provider. The only payments we receive are from our clients and are specified in the client contract. We do not accept commissions, soft dollars, 12(b)(1) fees or any other form of third-party payment. Tortoise is entirely independent. We have no house product. We do not engage in principal transactions. When you work with Tortoise, you will know precisely what you pay us and that our fees are not affected by investment selection or other relationships.

Tortoise manages its clients’ accounts on a discretionary basis, pursuant to written investment guidelines specified in the client contract.

Client accounts are registered separately in the clients’ names and are generally custodied at Fidelity Investments, except for employment–based retirement accounts (i.e. 401(k) accounts) which remain with the custodian specified in the employer’s plan. Client assets are never commingled or held in Tortoise’s custody.

Important Disclosure Information

Tortoise Investment Management, LLC (“Tortoise”) is an SEC registered investment adviser located in White Plains, New York. Tortoise and its representatives are in compliance with the current filing requirements imposed upon SEC registered investment advisers by those states in which Tortoise maintains clients. Tortoise may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements. 

Tortoise’s web site is limited to the dissemination of general information pertaining to its advisory services, together with access to additional investment–related information, publications, and links. Accordingly, the publication of Tortoise’s web site on the Internet should not be construed by any consumer and/or prospective client as Tortoise’s solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Any subsequent, direct communication by Tortoise with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. For information pertaining to the registration status of Tortoise, please contact the SEC or the state securities regulators for those states in which Tortoise maintains a notice filing. A copy of Tortoise’s current written disclosure statement discussing Tortoise’s business operations, services, and fees is available from Tortoise upon written request. Tortoise does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Tortoise’s web site or incorporated herein, and takes no responsibility therefor. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.

Please remember that different types of investments involve varying degrees of risk, and there can be no assurance that the future performance of any specific investment or investment strategy (including those undertaken or recommended by Tortoise), will be profitable or equal any historical performance level(s).

©2019 Tortoise Investment Management, LLC