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 small number of employee investment advisor representatives whose services are limited to servicing certain small XXX accounts. 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 program account on behalf of Advisor. That person is not acting in a broker-dealer capacity or on behalf of LPL with respect to services provided under this program. LPL has an arrangement with Fortigent, a registered investment advisor and related person of LPL. LPL and Fortigent have entered into an agreement for LPL to provide overlay portfolio management services to Fortigent clients in Fortigent’s Access Overlay II 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 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. Code of Ethics and Personal Trading LPL has adopted a code of ethics that includes guidelines regarding personal securities transactions of its employees and IARs. The code of ethics permits LPL employees and IARs to invest for their own personal accounts in the same securities that...
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 are 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 & Income Alpha strategy includes allocations to certain First Trust-sponsored ETFs. Confluence will from time ...
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. 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. Investment Company Private Fund
Other Financial Industry Activities and Affiliations. Mutual Fund: Other pooled investment vehicle(s):
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 Xxxxxxxx Advisors requires its supervised persons to consistently act in your best interest in all advisory activities. Xxxxxxxx Advisors imposes certain requirements on its affiliates and supervised persons to ensure that they meet t...
Other Financial Industry Activities and Affiliations. Mutual Funds:
