Legal Disclosures

LPL Conflicts of Interest

If you receive brokerage or advisory services from LPL Financial LLC ("LPL Financial"), you should be aware that LPL Financial's interests may not always be the same as yours.  LPL Financial is paid both by you and, sometimes, by other entities that compensate LPL Financial based on transactions for your account.  The disclosures below describe certain potential conflicts of interest that may apply to your account.  Please read these disclosures carefully and note that there may be additional conflicts of interest applicable to your specific accounts which are not addressed below.  Please ask us questions to make sure you understand your rights and LPL Financial's obligations to you as a brokerage or advisory client of an LPL Financial advisor. 

Sponsorship Programs

LPL Financial receives compensation (sometimes referred to as "revenue sharing") from mutual fund families, annuity issuers, alternative investment product sponsors, and retirement plan product sponsors in connection with their affiliated products that are available to the brokerage and advisory clients of LPL Financial's advisors. Compensation is paid in connection with programs that support our marketing and sales force education and training efforts, such as our annual national sales and education conference and other conferences (referred to here as " Sponsorship Programs").The mutual fund families, retirement plan product sponsors, alternative investment product sponsors, and annuity issuers that participate in the Sponsorship Programs (referred to here, as applicable, as "Participating Sponsors") are listed below. LPL Financial advisors do not receive any portion of these payments. In some cases, Participating Sponsors may pay additional marketing payments to LPL Financial and/or LPL Financial advisors to cover fees to attend conferences or reimbursement of expenses for workshops or seminars.

Mutual Funds and Variable Annuities

In addition to receiving commissions and other types of compensation, LPL Financial receives payments in connection with mutual fund and variable annuity transactions under the Sponsorship Programs, which are calculated based upon the assets and/or sales with the Participating Sponsor, including any 529 college savings plan assets. LPL Financial may receive compensation on an annual basis of up to 0.15 percent of assets invested in the mutual funds or variable annuities affiliated with a Participating Sponsor that are held by the clients of LPL Financial's advisors. For example, if you invest $10,000 dollars in a mutual fund for one year, LPL Financial could receive a payment of up to $15 from the affiliated mutual fund sponsor. In lieu of these payments, LPL Financial may receive up to 0.35 percent on sales of such products.  Mutual fund families participating in the Sponsorship Programs may incur a ticket charge of up to $10 per trade for purchases of mutual fund shares.

Mutual Fund Sponsors

  • Alliance Bernstein
  • Allianz Global Investors
  • American Beacon
  • American Century
  • American Funds Distributors
  • BlackRock
  • Calamos
  • Calvert Investments
  • Cohen & Steers Securities
  • Columbia Management
  • Compass
  • Delaware Investments
  • Dreyfus
  • Dunham
  • DWS Investments
  • Eaton Vance
  • Empiric Funds
  • Federated
  • Fidelity Advisor Funds
  • First Eagle
  • Forward Funds
  • Franklin Templeton Investments
  • Fred Alger & Company
  • Goldman, Sachs
  • Guardian Investor Services / RS Investments
  • Guggenheim
  • Hartford Life Distributors
  • Highland Capital Management
  • Highmark Capital Management
  • ICON Distributors
  • Invesco
  • Ivy Funds
  • Janus Capital Management
  • John Hancock Funds
  • JP Morgan Investment Management
  • Lazard Asset Management
  • Legg Mason Partners
  • Lord Abbett
  • Mainstay
  • Managers Investment Group
  • MFS
  • Morgan Stanley
  • NATIXIS
  • Neuberger Berman Management
  • Nuveen
  • Oppenheimer Funds
  • Pacific Life
  • PIMCO
  • Pioneer Investments
  • Principal Funds
  • Prudential
  • Putnam Investments
  • Russell Investments
  • Sentinel Investments
  • Stadion Money Management
  • Sun America
  • TIAA-CREF
  • Thornburg Investment Management
  • Touchstone Investments
  • Transamerica Capital
  • Transparent Value
  • Van Eck Securities Corporation
  • Virtus Investments
  • Voya Financial
  • Wells Fargo Funds Management

 When new mutual fund families join LPL Financial's advisory and brokerage platforms, they may be charged up to $40,000 as an initial setup fee.  When existing mutual fund families add new funds to LPL Financial's platforms, they may pay a one-time setup fee of up to $5,000 per fund.

Ticket charges may vary across LPL Financial's brokerage platform.  For mutual fund families indicated on the chart above, the ticket charge is waived completely for clients.

Shares of mutual funds offered by LPL Financial may be purchased without a ticket charge by processing the transaction with a check and application sent directly to the mutual fund company.

American Funds Distributors, Inc.

American Funds Distributors, Inc. may provide compensation to LPL Financial in accordance with the terms of our letter of understanding. These payments are made at the discretion of American Funds Distributors, Inc., will vary in any given year, and represent the sum of (a) 0.10 percent of the previous year's American Funds sales by LPL Financial and (b) 0.02 percent of American Funds assets held by the clients of LPL Financial's advisors. The actual payment to LPL Financial in any given year will depend on LPL Financial's sales, assets and redemption rates, and our relationship with American Funds.

Variable Annuity Sponsors

  • Allianz Life Financial Services, LLC
  • AXA
  • Forethought
  • Guardian Investor Services
  • Integrity Life Insurance
  • Jackson National Life Insurance
  • John Hancock Life Insurance 
  • Lincoln Financial
  • MetLife Investors Insurance
  • Nationwide Life Insurance
  • Ohio National Financial Services
  • Pacific Life Insurance
  • Penn Mutual
  • Pioneer Investments
  • Protective Life Insurance
  • Prudential Annuities
  • RiverSource Life Insurance
  • Sammons Financial Group
  • Sun Life Financial
  • SunAmerica Life Assurance Company
  • Symetra Life Insurance Company
  • Transamerica
  • Voya Financial (formerly known as ING)


Fixed Annuities

LPL Financial receives compensation from fixed annuity sponsors that are available to brokerage clients of LPL Financial advisors. In addition to commissions and trailing commissions (which vary depending on the product), LPL Financial receives payments from fixed annuity sponsors under the Sponsorship Programs that are based on sales or on the paid premiums LPL Financial may receive compensation of up to 0.50 percent of fixed annuity paid premiums. For example, if you held $10,000 dollars with a sponsor for one year, LPL Financial could receive compensation of up to $50 from that sponsor. LPL Financial shares commissions and trailing commissions with LPL Financial advisors but does not share with LPL Financial Advisors any portion of the compensation paid under the Sponsorship Programs.

Fixed Annuity Sponsors

  • Allianz
  • Allstate Life Insurance Company
  • American National Insurance Company
  • AXA Distributors, LLC 
  • Brooke Life Insurance Company
  • Commonwealth Annuity & Life Insurance Company
  • Forethought
  • Genworth Life and Annuity Insurance Company
  • Great American Life
  • Jackson National Life Insurance Company
  • John Hancock
  • MetLife Investors Distribution Company
  • Midland National Life Insurance Company
  • New York Life Insurance and Annuity Corporation
  • Ohio National Financial Services
  • Pacific Life Insurance Company 
  • Principal Life Insurance Company
  • Protective Life Insurance Company
  • Reliance Standard Life Insurance Company
  • Sun Life
  • Symetra Life Insurance Company
  • Voya Financial (formerly known as ING)
  • Western & Southern Financial Group, Inc. / Integrity 
  • Western National (AIG)


Retirement Plan Sponsors

LPL Financial may receive marketing and educational support payments of up to $300,000 per year from retirement plan product sponsors to assist training and educating financial advisors across LPL Financial's advisory and brokerage platforms. This compensation is not tied to the sales of any products. LPL Financial advisors do not receive any portion of these payments.

  • ADP
  • Alianz Global Investors
  • American Beacon
  • American Century
  • American Funds
  • Ascensus
  • AUL/One America
  • AXA
  • BlackRock
  • BNY Mellon/Dreyfus
  • Columbia Management
  • CUNA
  • Eaton Vance Investment Managers
  • Empower Retirement
  • ExpertPlan Retirement Services
  • Fidelity Investments
  • Franklin Templeton Investments
  • Goldman Sachs
  • Great West
  • Guardian Investor Services
  • Invesco
  • Ivy Funds
  • Janus Capital Management LLC
  • John Hancock retirement Services
  • John Hancock Funds
  • JP Morgan Investment Management
  • Legg Mason
  • Lincoln Financial
  • Mainstay Funds
  • Manning & Napier
  • Mass Mutual
  • MFS Investment Management
  • Mutual of Omaha
  • Nationwide Financial Retirement Plans
  • Natixis Global Asset Management
  • Neuberger Berman
  • Nuveen
  • NYLIM
  • Oppenheimer Funds
  • Paradigm Capital Management
  • PIMCO
  • Pioneer Investments
  • Principal Financial Group
  • Principal Funds
  • Prudential
  • Putnam
  • Ridgeworth Investments
  • RS Investments
  • Security Benefit
  • Standard Retirement Services
  • TIAA-CREF Financial Services
  • Thornburg
  • Transamerica Retirement Services
  • Valic
  • Vanguard
  • Verisight, Inc.
  • Voya Financial (formerly known as ING)
  • Wells Fargo Funds

 

Alternative Investment Products

In addition to compensation for the sale of non-publicly traded products, including non-traded real estate investment trusts ("REITs"), limited partnerships ("LPs"), and 1031 exchange programs; hedge funds and fund of funds; managed futures; tax credit programs; oil and gas programs; venture capital funds; and private equity funds, LPL Financial may receive due diligence and/or marketing allowance payments from certain sponsors.

While the arrangements may vary, each alternative investment product sponsor may pay a due diligence or marketing allowance fee of either (a) up to 0.60 percent per year of clients' assets held at the sponsor and/or (b) up to 1.50 percent on sales (also called "placement fees" or "investor servicing fees"). LPL Financial advisors do not receive any portion of this due diligence or marketing allowance fee. 

  • ACAP Strategic Fund
  • Alkeon
  • Altegris
  • Atlas Energy
  • Campbell and Company
  • Central Park Group
  • Chadwick
  • CNL
  • Cole Capital
  • Cross Shore Capital Management, LLC
  • Cypress
  • Dearborn Capital Management
  • Dunbar Capital
  • Franklin Square
  • Gorelick Brothers Capital
  • Gottex Fund Management
  • GrantPark
  • Hatteras
  • Hines
  • ICON Investments
  • Macquarie Group
  • Octavus
  • Skybridge
  • Steben & Company, Inc.
  • Strategic Capital Solutions (SCS)

 

Life Insurance Compensation Disclosure

LPL Financial receives compensation from issuers of life insurance (universal, variable universal, whole life, and term) and other insurance contracts that are available to brokerage clients. The compensation includes commissions and trailing commissions, and may include payments for administrative services that LPL Financial provides and payments made in connection with LPL Financial's marketing and sales-force education and training efforts, including LPL's annual national sales and education conference and other conferences. LPL and/or its affiliated insurance agency, LPL Insurance Associates, Inc. ("LPLIA"), receive commissions in the range of 4% to 110% of first-year commissionable premiums. LPL Financial may also receive a trailing commission in the range of 1% to 10% on an annual basis. The amount of commission varies depending on the issuer, coverage and the premium amount. In addition, LPL may receive from the following issuers up to 10% of first-year commissionable premiums for marketing, training, and supporting distribution of the issuer's insurance products offered through LPL Financial as a broker-dealer. For business placed through LPLIA, LPLIA typically receives between 10% to 25% of first-year commissionable premiums to support the additional case-management services that LPLIA provides for products offered through LPLIA. LPL Financial advisors receive a percentage of the commissions and trailing commissions the insurance company pays to LPL Financial and/or LPLIA. LPL Financial, LPLIA, and LPL Financial advisors may also receive additional compensation from issuers whose aggregate sales exceed premium thresholds specified in selling agreements with LPL Financial and/or LPLIA.  

Variable Universal Life, Fixed Life, and Long Term Care & Disability Insurance Carriers

  • Allstate Life Insurance Company
  • Allstate Life Insurance Company of New York
  • American General
  • American General Life Insurance Company of Delaware
  • American National Insurance Company
  • Ameritas (formerly known as Union Central)
  • Assurity Life
  • Aviva Life and Annuity
  • Aviva Life and Annuity Company of New York
  • AXA Equitable Life Insurance Company
  • First Symetra National Life Ins. Co. of New York
  • ForeThought
  • General American Life
  • Genworth Life Insurance Co. of NY
  • Genworth Life Insurance Company
  • Golden Rule
  • Great West Life
  • John Hancock
  • John Hancock NY
  • Legal and General America (Banner & William Penn)
  • Liberty Life Assurance Company of Boston
  • Lincoln Benefit
  • Lincoln Life & Ann of NY
  • Lincoln National Life Insurance Company
  • MassMutual
  • MetLife DI
  • Metropolitan Life Insurance Company
  • Midland National
  • Mutual of Omaha (United of Omaha)
  • Nationwide Life
  • New York Life
  • Ohio National Life
  • OneAmerica
  • Pacific Life Ins
  • Penn Mutual Life Ins
  • Principal Life
  • Protective Life Insurance
  • Prudential Life Insurance Co.
  • Reliastar Corporation
  • Reliastar Life of NY
  • SBLI Mutual Life Insurance Company, Inc.
  • Security Life of Denver
  • Standard Insurance Company
  • State Life Insurance Co.
  • Symetra Life Insurance Co.
  • Transamerica Life Insurance Company
  • United Life Insurance Company
  • The United States Life Insurance Company in the City of New York
  • Vantis Life Insurance Company
  • Voya Financial (formerly known as ING)
  • West Coast Life
  • Western & Southern Financial Group
  • William Penn


Record Keeping Fees

LPL Financial receives compensation from mutual fund families for providing certain recordkeeping and related services to the funds.  A type of recordkeeping service that LPL Financial provides to certain mutual fund families is to process transactions on an "omnibus" basis, which means LPL Financial consolidates its advisors' clients' trades into one daily trade with a fund, and therefore maintains all pertinent individual shareholder information for the fund. Trading in this manner requires that LPL Financial maintain the transaction history necessary to track and process sales charges, annual service fees, and applicable redemption fees and deferred sales charges for each position, as well as other transaction details required for ongoing position maintenance purposes. For these services, funds may pay up to $25 per year per position or up to 0.25 percent per year of fund assets held by the clients of LPL Financial advisors in brokerage accounts and advisory accounts.

If LPL Financial does not provide omnibus services to a mutual fund family, then fund shares are traded on a networked basis, which means LPL Financial submits a separate trade for each individual client trade to the fund and, therefore, LPL Financial maintains only certain elements of the fund's shareholder information. We charge these funds a networking fee of up to $12 per year per position held by the clients of LPL Financial advisors.

Although LPL Financial provides additional services to funds where positions are held on an omnibus basis, the fact that the fee rate is greater for omnibus services than the rate for networked services presents a potential conflict of interest for LPL Financial as it would have an incentive to recommend purchases of omnibus-traded funds over networked funds.  LPL Financial advisors do not receive any portion of these payments.  Funds that trade omnibus through LPL Financial's platforms may carry a reduced ticket charge. 

Mutual Funds Families Trading Omnibus With LPL Financial

  • 1290
  • 1492
  • 361
  • AAM
  • Aberdeen
  • Absolute
  • Academy
  • Adirondack
  • Alger
  • AllianceBernstein
  • Allianzgi
  • Alphacentric
  • Alpine
  • Altegris
  • America First
  • American Beacon
  • American Centiry
  • American Funds
  • American Independence
  • AMG
  • ANfield
  • API
  • Appleseed
  • AQR
  • Arbitrage
  • Arden
  • Aristotle
  • Artisan
  • Ascentia
  • Ashmore
  • Aston
  • Aurora
  • Avenue
  • Azzad
  • Babson
  • Baron
  • BBH
  • Beck, Mack & Oliver
  • Berwyn
  • Blackrock
  • BMO
  • BP Capital
  • BPV
  • Brandywine
  • Bright Rock
  • Brinker
  • Brookfield
  • Buffalo
  • Calamos
  • Calvert
  • Camelot
  • Capital Advisors
  • Capital Innovations
  • Carne
  • Catalyst
  • Center Coast
  • CGM
  • Cohen & Steers
  • Columbia
  • Compass Emp
  • Congress
  • Convergence
  • Copeland
  • Credit Suisse
  • CRM
  • Currency Strategies
  • Cutler
  • Davis
  • Day Hagen
  • Dean
  • Dearborn Partners
  • Delaware
  • Delux
  • Destra
  • Deutsche
  • DFA
  • Diamond Hill
  • Direxion
  • Dreyfus
  • Driehaus
  • Eagle
  • Eaton Vance
  • Elessar
  • Empiric
  • Eventide
  • Evergreen
  • Evermore
  • FBR
  • Federated
  • Fidelity Advisors
  • First Eagle
  • First Trust Series
  • Firsthand
  • Forward
  • FPA
  • Franklin Templeton
  • Gabelli
  • Gavekal
  • GE Institutional
  • Geneva Advisors
  • Gerstein Fisher
  • Goldman Sachs
  • Good Harbor
  • Grant Park
  • Guggenheim
  • Hansberger
  • Harbor
  • Hartford
  • Henderson Global
  • Hennessy
  • Highland
  • Highmark
  • Horizon
  • Hotchkis & Wiley
  • Huntington
  • Icon
  • Innealta
  • Invesco
  • IronHorse
  • Ivy
  • Jag
  • James
  • Janus
  • John Hancock
  • JP Morgan
  • Keeley
  • Kinetics
  • Lateef
  • Laudus
  • Lazard
  • Leader
  • Lee Munder
  • Legg Mason
  • Liberty Street
  • Litman Gregory
  • Lo Corr
  • Longboard
  • Longleaf
  • Loomis Sayles
  • Lord Abbett
  • M.D. Sass
  • Madison
  • Mainstay
  • Mairs And Power
  • Marsico
  • Matthews
  • Merger
  • Meridian
  • Metropolitan West
  • Metropolitan West Class I
  • MFS
  • Miller
  • Mirae Asset Discovery
  • Morgan Stanley
  • Morgan Stanley Inst
  • Motley Fool
  • Munder
  • Nationwide
  • Natixis
  • Neuberger & Berman
  • Northern
  • Newfound
  • Northpointe
  • Nuance
  • Nuveen
  • Oak Assoc.
  • Oak Ridge
  • OakMark
  • Oakseed
  • Oppenheimer
  • Optimum
  • Orinda
  • Pacific Life
  • Paradigm
  • Parnassus
  • Pax World
  • Pension Partners
  • PIMCO
  • Pioneer
  • Poplar Forest
  • Praxis
  • Primecap
  • Principal
  • Profunds
  • Prudential
  • PTA
  • Putnam
  • Quaker
  • Rainier
  • RBB-Abbey Capital
  • Redwood
  • Ridgeworth
  • Riverbridge
  • Riverpark
  • Robinson
  • Royce
  • RS
  • Russell
  • Salient
  • Schwab
  • Scout
  • SEI
  • Selected
  • Semper
  • Sentinal
  • Sierra
  • Signalpoint
  • Sim
  • Smead
  • Stadion
  • Sterling Capital
  • Sun America
  • Symons Capital
  • T Rowe Price
  • TCW
  • Third Ave
  • Thornburg
  • TIAA-CREF
  • Timberline
  • Tocqueville
  • Toroso
  • Touchstone
  • Towes
  • Towle
  • Transamerica
  • Transparent Value
  • Turner
  • Tweedy Browne
  • US Global Investors
  • Van Eck
  • Victory
  • Voya Financial (formerly known as ING)
  • VRM
  • Wasatch
  • WBI
  • Weitz
  • Wells Fargo Adv
  • Western Asset
  • West Loop
  • Whitebox
  • WHV
  • William Blair
  • Zacks
  •  

     

    Mutual Fund Networking/Annuity Networking

    When LPL is the broker-dealer on the books and records of a mutual fund or variable annuity, the fund or annuity or an affiliate of the fund or annuity may pay LPL a networking fee that is based on the number of LPL client positions held in the fund or annuity (up to $12 per position per year) or amount of client assets in the fund (up to 0.15% on an annual basis). LPL may charge mutual fund or variable annuity product sponsors a one-time networking setup fee to reimburse LPL for associated technology-related costs.

    Networked Mutual Fund Families

    • Aberdeen
    • Allegiant/PNC
    • Alger
    • Alliance Bernstein
    • Allianz
    • ALPS
    • American Beacon Advisors
    • American Funds
    • American Growth
    • Archer
    • Ashmore
    • Baird & co.
    • Baron Capital
    • Brandes
    • Burnham
    • Capital Investment Group
    • Cohen & Steers
    • Colorado Bond Shares/Freedom
    • Columbia
    • Credit Suisse
    • Davis
    • Diamond Hill
    • Doubleline
    • Dreyfus
    • Driehaus
    • Dunham & Associates (Kelmoore)
    • Deutsche Asset Management
    • Eagle
    • Eaton Vance
    • Emerald Growth
    • Empiric Funds
    • Fidelity
    • First Pacific Advisors
    • FIrst Trust Portfolios
    • Forward
    • Franklin Templeton
    • Fund X Upgrader (Professionally Managed Portfolios)
    • Global Asset Management
    • Goldman Sachs
    • GoodHaven
    • Gottex
    • RS Investments
    • Hartford
    • Henderson Global
    • Highland
    • Hotchkis & Wiley
    • HSBC
    • Huntington Asset Services (American Pensions Investors Trust)
    • Hussman
    • ICON
    • Invesco
    • Jackson National
    • Keeley
    • Lazard
    • Leader Funds
    • Leuthold
    • LoCorr
    • Maingate
    • Mainstay
    • Managers
    • Manning Napier
    • Matrix Capital Corp
    • Members/CUNA (Madison)
    • MFS
    • Mirae
    • Munder (Acquired by Victory)
    • Nationwide
    • Natixis
    • Neuberger
    • Northern Lights
    • Nuveen
    • Olstein
    • Pacific Global
    • Pacific Heights
    • Pacific Select
    • Payden
    • PIMCO
    • Pioneer
    • Principal Funds
    • Putnam
    • Quaker
    • Ridgeworth
    • Robeco
    • Rochdale
    • Russell
    • Rydex
    • Schooner
    • Sun America
    • Sentinel
    • Thornburg
    • Touchstone
    • Transamerica Fund Services Inc.
    • T. Rowe
    • Turner
    • UBS
    • Van Den Berg
    • TFS Capital
    • Van Eck Securities Corp
    • Virtus
    • Wells Fargo
    • Willmington
    • Wright INvestors'

     

    Networked Annuities

  • Allianz
  • AXA
  • Forethought
  • Genworth/span>
  • Great American Life Insurance Company
  • Guardian
  • Integrity
  • Jackson National
  • Lincoln National
  • MetLife
  • Nationwide
  • National Security Life
  • New York Life
  • Ohio National Life
  • Pacific Life
  • Penn Mutual Life
  • Principal Life
  • Protective
  • Prudential
  • River Source
  • Security Benefit
  • Sun America
  • Sun Life
  • Symetra
  • Transamaerica
  • Western National (AIG)
  • Western & Southern
  • Voya Financial (formerly known as ING)
  •  

    Additional Compensation to LPL Financial

    Money Market Mutual Fund Automatic Cash Sweep Program

    For accounts that are ineligible for the Insured Cash Account ("ICA") program as the automatic cash sweep vehicle, LPL Financial offers an automatic cash sweep money market mutual fund program. The money market mutual fund automatic cash sweep program sweeps uninvested cash daily into taxable and tax-exempt money market funds offered by J.P. Morgan Asset Management and Federated Services Company. LPL Financial may receive compensation of up to 0.16 percent of the assets invested in J.P. Morgan Asset Management money market funds and up to 0.35 percent of the assets invested in Federated Services Company money market funds. LPL Financial advisors do not receive any portion of these payments.

    High Cash Balance Options Program

    LPL Financial also offers a High Cash Balance Options ("HCBO") program for ICA-eligible accounts with large amounts of cash to invest (non-ICA eligible accounts may participate on an exception basis). ICA-eligible accounts with a $250,000 minimum in cash for investment may purchase any one of four money market funds and retain the ICA sweep on the account (the $250,000 minimum applies to the amount of the cash trade). LPL Financial may receive compensation of up to 0.06 percent of the assets invested in the HCBO program money market funds. LPL Financial advisors do not receive any portion of these payments.

    Optimum Funds

    LPL Financial serves as a sub-services agent to the Optimum Funds, providing sub-accounting and shareholder recordkeeping with respect to Optimum Fund shares. LPL Financial receives compensation of $16 per account for assets held at LPL Financial for these services. As an investment consultant to Delaware Investments, the investment advisor to the Optimum Funds, LPL Financial also provides investment consulting services to the advisor of the Optimum Funds. As compensation for these services, LPL Financial receives an investment consulting fee of up to 0.285 percent on all Optimum Fund assets. LPL Financial advisors do not receive any portion of these payments. For more information regarding our investment advisory activities, please consult LPL Financial's Form ADV.

    Strategic Wealth Management (SWM) Program

    For LPL Financial's registered investment advisor (RIA) custodial platform (SWM), LPL Financial may receive additional compensation (exclusive of 12b-1 payments) of up to 0.40 percent of mutual fund assets held with a sponsor. Fund companies that pay LPL Financial additional compensation payments may receive reduced ticket charges for their funds on the SWM platform. RIAs using the SWM platform do not receive any part of these payments.

    Third-Party Investment Advisors

    LPL Financial enters into agreements with Turnkey Asset Management Program ("TAMP") sponsors and Third-Party Investment Advisers ("TPIA") to whom LPL Financial advisors refer clients, pursuant to which LPL may provide (i) marketing services on behalf of TPIA and TAMP to LPL Financial advisors; and/or (ii) data technology services to integrate TPIA and TAMP account data on LPL's technology systems. LPL Financial receives fees for these data technology services and such fees may be a flat upfront or annual fee or be based on the amount of assets (typically up to 0.20%) recommended or referred by LPL Financial to TPIA or TAMP sponsor. The TPIA and TAMP sponsors who pay such fees include Aris, Brinker, Clark Capital, Curian Capital, Hanlon, ICON, ITS, Niemann, Portfolio Strategies, and Potomac. LPL Financial advisors do not share in these fees.

    Investor Presentation & Proposal Tool (IPPT) Disclosure

    LPL Financial offers IPPT, a free web-based tool, to LPL Financial advisors to create customized client presentations that may include investment recommendations based on all of LPL Financial's advisory platforms. LPL Financial receives reimbursement from certain product sponsors for technology-related costs associated with the development and ongoing maintenance of the IPPT software. The product sponsors that participate in this initiative are: American Funds Distributors, Inc., Deutsche Asset Management, John Hancock Funds, Natixis, Nuveen, and Voya Investment Management. LPL Financial advisors do not receive any portion of these payments.

    Other conflicts of interest can be found in LPL Financial's Form ADV, available at http://www.adviserinfo.sec.gov