Other Financial Industry Activities and Affiliations. LPL is a broker-dealer registered with FINRA and the SEC. As a broker-dealer, LPL transacts business in various types of securities, including mutual funds, stocks, bonds, commodities, options, private and public partnerships, variable annuities, REITs and other investment products. LPL is registered to operate in all 50 states and has primarily an independent-contractor sales force of registered representatives and investment advisor representatives dispersed throughout the United States. LPL has a dedicated team of employee IARs in its home office who service certain accounts in the absence of an IAR, and also a small subset of IARs who operate their own offices or are located on the premises of certain financial institutions and are employees of LPL Employee Services, LLC, an LPL-affiliated company. If required for their positions with a registered broker-dealer, LPL’s principal executive officers are securities licensed as registered representatives of LPL. LPL is also registered as a transfer agent with the SEC and as an introducing broker with the Commodity Futures Trading Commission. In addition, LPL is qualified to sell insurance products in all 50 states. Associated persons of Advisor may also be broker-dealer registered representatives of LPL or another broker-dealer. If an associated person of Advisor is a broker-dealer registered representative of LPL, that person is providing advisory services to the program account on behalf of Advisor. That person is not acting in a broker-dealer capacity or on behalf of LPL with respect to the services provided under this program. LPL and The Private Trust Company, N.A. (“PTC”), a federally chartered non-depository bank licensed to provide trust services in all 50 states, are related persons. PTC serves as XXX custodian for program accounts set up as IRAs and receives an annual maintenance fee for this service. PTC also provides personal trustee services to clients for a variety of administrative fiduciary services, which services may relate to a program account. Because LPL and PTC are affiliated companies and share in revenues, there is a financial benefit to the companies if a client uses PTC as a custodian or for personal trustee services, or if a PTC client uses LPL as an investment advisor. PTC’s XXX custodian and trustee services and related fees are established under a separate engagement between the client and PTC. LPL and Xxxxx & Company of Florida, LLC (“Xxxxx & Co.”), an investment advisor firm,...
Other Financial Industry Activities and Affiliations. Confluence professionals from time to time assist other financial services organizations through providing advisory services for which they can be remunerated. These outside business activities are vetted by management prior to an employee’s involvement and routinely reviewed to ensure Confluence clients are not disadvantaged. Xxxx Xxxxxx, CEO and Chief Investment Officer of Confluence, is a member of the board of directors of Xxxxxxxx Xxxxxxx, Inc. (“BEI”), the holding company of Xxxxxxxx X. Xxxxxxx & Company (“BFEC”) and Xxxxxxx Wealth Management (“EWM”). Xx. Xxxxxx has a private investment in the equity securities of BEI. Although he has no day-to-day decision-making responsibilities for BEI, as a member of their board of directors he is involved in the development of strategy, policy and other important matters affecting the firm. Confluence offers its discretionary and non-discretionary investment advisory services to BFEC, EWM and their clients, as described above under Item 4 of this Brochure, titled Advisory Business. As part of Xx. Xxxxxx’x professional responsibilities with Confluence, he is involved in making investment decisions concerning portfolios of individual clients of BFEC and EWM. BFEC and EWM and their representatives do not receive any additional or different sales compensation in connection with recommendations to clients concerning Confluence versus any Financial Institution in comparable circumstances. Confluence and Xx. Xxxxxx do not receive any additional compensation in connection with client investments placed with Confluence through BFEC and EWM due to Xx. Xxxxxx’x position on the board. Xx. Xxxxxx is compensated for his service as a board member of BEI on the same terms as other independent board members. Xxxxx Xxxxxx, President and Chief Operating Officer of Confluence, is the sole owner of Xxxxxx Investment Partners LLC (“HIP”). HIP provides non-investment advisory services to corporate clients for which it receives fixed fees. HIP and Confluence have a mutual client: First Trust Portfolios L.P. (“First Trust”), a Financial Institution for which Confluence provides discretionary portfolio management and investment advisory services by acting as a sub-advisor to an open- end mutual fund and a closed-end fund for which an affiliate of First Trust serves as investment adviser. Additionally, the Confluence Growth and Income Alpha Strategy includes allocations to certain First Trust sponsored ETFs. Confluence may from time to ti...
Other Financial Industry Activities and Affiliations. LPL is a broker-dealer registered with FINRA and the SEC. As a broker-dealer, LPL transacts business in various types of securities, including mutual funds, stocks, bonds, commodities, options, private and public partnerships, variable annuities, REITs and other investment products. LPL is registered to operate in all 50 states and has primarily an independent-contractor sales force of registered representatives and IARs dispersed throughout the United States. LPL has a dedicated team of employee IARs who service certain accounts in the absence of an IAR. IARs are registered representatives of LPL. If required for their positions with a registered broker-dealer, LPL’s principal executive officers are securities licensed as registered representatives of LPL. LPL is also registered as a transfer agent with the SEC and as an introducing broker with the Commodity Futures Trading Commission. In addition, LPL is qualified to sell insurance products in all 50 states. LPL and The Private Trust Company, N.A. (“PTC”), a federally chartered non-depository bank licensed to provide trust services in all 50 states, are related persons. PTC serves as XXX custodian for program accounts set up as individual retirement accounts. PTC also provides personal trustee services to clients for a variety of administrative fiduciary service, which services may relate to a program account. PTC’s XXX custodian and trustee services and fees are established under a separate engagement between the client and PTC. IARs are permitted to engage in certain LPL-approved business activities other than the provision of brokerage and advisory services through LPL, and in certain cases, an IAR could receive greater compensation through the outside business than through LPL. An IAR could also be an accountant, real estate agent, tax preparer, lawyer or refer customers to other service providers and receive referral fees, for example. As other examples, an IAR could provide advisory or financial planning services through an independent unaffiliated investment advisory firm, sell insurance through a separate business, or provide third-party administration to retirement plans through a separate firm. If an IAR provides investment services to a retirement plan as a representative of LPL and also provides administration services to the plan through a separate firm, this typically means the IAR is compensated from the plan for the two services. If you engage with an IAR for services separate from LPL, y...
Other Financial Industry Activities and Affiliations. Mutual Fund: As previously disclosed in "Advisory Business" (Item 4) and "Fees and Compensation" (Item 5) of this brochure, we are the investment advisor to the IRON Strategic Income Fund and the IRON Equity Premium Income Fund, both are investment companies registered under the Investment Company Act of 1940. We are related to these Mutual Funds through common control. Please refer to these items for a detailed explanation of this relationship and important conflict of interest disclosures. For additional information, the Fund Prospectus and Statement of Additional Information are available on-line at: xxxxxxxxx.xxx. Prospective investors should review these documents carefully before making any investment in the Mutual Fund. Other pooled investment vehicle(s): IRON Financial LLC, is also affiliated with IRON Corporate Retirement Services, LLC and IRON
Other Financial Industry Activities and Affiliations. Hyas Group does not receive revenue from any money management firms, recordkeepers or other retirement plan service providers. Our only compensation is that which we receive directly from our clients. Hyas Group and its representatives may provide services to clients that are not investment advisory in nature. These services may include reporting on investments and account or plan assets, consulting on noninvestment matters, education, vendor search projects, and performance review and evaluation.
Other Financial Industry Activities and Affiliations. Creative Planning is an independent investment advisory firm and provides investment advisory services and other ancillary services described below. The firm does not offer any proprietary products, does not have an affiliated broker-dealer, and is not engaged in any other business activities and offers no services other than those described in this Disclosure Brochure. Our investment advisor representatives are not affiliated (which means registered or employed) with a broker/dealer or commodities and futures trading firm.
Other Financial Industry Activities and Affiliations. Investment Company As noted in Item 4 above, XXXXXXX is the investment adviser to the Sparrow Funds. XXXXXXX does not believe these advisory services create material conflicts of interest between the Firm and its other clients. Xxxxxx X. Xxxxxxx serves as Chief Compliance Officer (“CCO”) of BYW Investment Advisors, Inc. (“BYW”). Xx. Xxxxxxx is also a sub-investment advisor with BYW. The accounts under BYW and SPARROW may have the same securities at certain times. BYW and SPARROW will block the trades if possible. If the trading cannot be done as a block, the trading order will be rotated. The CCO or other designated compliance personnel will review all trades to ensure one client does not have an advantage over another. BYW currently sub-leases from and shares office space with SPARROW on a monthly basis. Xx. Xxxxxxx owns 1% of BYW’s capital stock. Xx. Xxxxxxx will attempt, on a best efforts basis, to avoid conflicts of interest between the accounts of BYW’s clients and the accounts of XXXXXXX and its clients; however, there can be no assurance that such conflicts will not occur. Private Fund Also, as noted in Item 4 above, Xxxxxx X. Xxxxxxx is the sole general partner of SPLP, the Private Fund. Sparrow Fund L.P. has an incentive based compensation schedule and may cause conflicts of interest with other services. These conflicts are mitigated by full disclosure.
Other Financial Industry Activities and Affiliations. Mutual Funds: As previously disclosed in Advisory Business (Item 4) and Fees and Compensation (Item 5) of this brochure, we are the investment advisor to the IRON Strategic Income Fund an investment company registered under the Investment Company Act of 1940. We are related to this Mutual Fund through common control. Please refer to these items for a detailed explanation of this relationship and important conflict of interest disclosures. For additional information, the Fund Prospectus and Statement of Additional Information are available on-line at xxx.xxxxxxxxx.xxx. Prospective investors should review these documents carefully before making any investment in the Mutual Funds.
Other Financial Industry Activities and Affiliations. IARs of Xxxxxxxx Advisors are registered representatives of Mid Atlantic Capital Corporation, Inc. (“Mid Atlantic”), a full-service securities broker-dealer licensed under federal and state securities laws, located in Pittsburgh, Pennsylvania. Mid Atlantic is a member of FINRA and the SIPC. In their capacity as registered representatives, such IARs are involved in the sale of securities of various types, including, but not limited to, stocks, bonds, and mutual funds. These individuals will receive normal and customary commissions as a result of securities transactions. Assets held directly at mutual funds, annuities or broker-dealer brokerage accounts may pay 12b-1 fees, ticket charges and other commission compensation to registered representatives. As such, a potential conflict of interest may exist between the interests of Xxxxxxxx Advisors, its IARs, and the interests of the client. In addition, IARs may also be insurance licensed and, as such, may assist clients with implementing insurance recommendations. If a client elects to purchase recommended insurance products through Xxxxxxxx Advisors and its IARs in their separate capacity as licensed insurance agents, such individuals will receive normal and customary commission- based compensation. As such, a potential conflict of interest may exist between the interests of Xxxxxxxx Advisors, its IARs, and the interests of the client. None of the IARs is an agent for a specific insurance provider; all insurance recommendations are made with the client’s best interests in mind. Additionally, clients are welcome to take such recommendations and implement the insurance recommendations at other insurance agencies separate and apart from Xxxxxxxx Advisors. Clients are under no obligation, contractually or otherwise, to purchase or sell securities and/or insurance products through Xxxxxxxx Advisors or its IARs. However, if the client freely chooses to do so through Xxxxxxxx Advisors the broker-dealer used will be Mid Atlantic, and commissions will be earned in addition to any fees paid for advisory services. The commissions may be higher or lower at Mid Atlantic than at other broker/dealers. ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics Summary According to the Investment Advisers Act of 1940, an investment adviser is considered a fiduciary and has a fiduciary duty to all clients. Xxxxxxxx Advisors has established a Code of Ethics to comply with the re...
