THIRD-PARTY FEE DISCLOSURE
Cadaret Grant & Co., Inc. (“Cadaret Grant”) receives compensation and/or fees (also referred to as revenue sharing or marketing support) from a number of mutual fund families, insurance companies, exchange traded fund (ETF) and alternative investment (real estate investment trusts (REITs), business development companies (BDCs), etc.) sponsors, and unaffiliated investment advisers that sponsor, manage, and/or promote the sale of certain products that are available to our customers. These payments include commissions, trailing commissions, fees, and for certain product sponsors, revenue sharing payments made in connection with programs that support our marketing and sales force education and training efforts (the “Partners Program”). These relationships provide additional compensation to Cadaret Grant that is used to offset a variety of expenses, including marketing, training, educational presentations, and other support. This additional compensation creates a conflict of interest as it influences the selection of investments and services Cadaret Grant and/or our financial professionals offer or recommend to customers. This disclosure is intended to provide you with an overview of the various types of compensation and fees Cadaret Grant & Co receives. We encourage you to review this information in its entirety and contact us with any questions.
CADARET GRANT REGULATION BEST INTEREST DISCLOSURES
Our Partners Program participants (“Partners”) are listed below. Partners pay Cadaret Grant different amounts of revenue sharing and receive different levels of benefits for such payments. Revenue sharing fees are not shared with our financial professionals. A financial professional’s compensation is the same regardless of whether a sale involves a Partner’s product. In some cases, Partners pay additional marketing payments to Cadaret Grant to cover fees to attend conferences or reimburse expenses for workshops or seminars. The payments made under the Partners Program are calculated based either on gross sales or assets under management or on a flat fee arrangement and vary by Partner. The benefits Partners receive include financial professional access and contact lists, business metrics, preferred placement on our website, participation in product training initiatives and marketing and sales campaigns, and the ability to participate in our conferences.
We use the revenue from our Partners to support certain marketing, training, and educational initiatives including our annual National Educational Conference. The conference provides a venue to communicate new products and services to our financial professionals, to offer training to them and their support staff, and to keep them abreast of regulatory requirements. The revenue is also used to pay for annual awards (in the form of a trophy, medal, or plaque) for our financial professionals who generate the most revenue overall and to pay for our general marketing expenses. Revenue from Partners helps to pay for top producer conference costs. Top producing Cadaret Grant financial professionals receive an award based on total sales, including sales of Partners’ mutual funds and ETFs.
MUTUAL AND ETF FUND PARTNERS
In addition to receiving sales commissions and other types of compensation, Cadaret Grant receives a flat fee, asset-based and/or sales-based compensation from our mutual fund and ETF Partners. Such payments vary by Partner. We receive payments from certain mutual fund Partners of up to 0.20% annually on sales and up to 0.0032% on assets. The following mutual fund and ETF sponsors currently participate in the Partners Program:
BTS Asset Management
iShares by Blackrock
PGIM (Prudential Global Investment Management)
Sammons Retirement Solutions
We prepare and make available to our financial professionals a quarterly list of Partners’ mutual funds and ETFs that have been screened for investment performance against other Partners’ funds with similar objectives and asset classes (the “Select Fund List” or “List”). Cadaret Grant and our financial professionals have a conflict of interest when a Financial Professional chooses or recommends an investment from the Select Fund List for your portfolio because Cadaret Grant receives revenue sharing fees from the mutual fund or ETF sponsor. Our receipt of revenue sharing fees influences our selection of mutual funds and ETFs, as our financial professionals are likely to choose or recommend a fund or ETF whose sponsor pays us revenue sharing fees over a fund or ETF whose sponsor does not pay us.
You do not pay more to purchase funds from the List through Cadaret Grant than you would pay to purchase these funds through another broker-dealer, and your financial professional does not receive additional compensation for selecting a fund from the List. Our financial professionals are not required to choose or recommend investments from the Select Fund List.
VARIABLE AND INDEXED ANNUITY PARTNERS
In addition to receiving commissions, Cadaret Grant receives flat fee and/or sales-based compensation from certain variable, fixed and indexed annuity Partners. Cadaret Grant receives compensation on an annual basis of up to 0.25% on variable and up to 0.75% on fixed and indexed annuity sales.
The following variable, fixed, and indexed annuity sponsors currently participate in the Partners Program:
Global Atlantic Financial Group
Midland National Life/Sammons Financial Nationwide
New York Life
FIXED INCOME AND STRUCTURED PRODUCTS
Cadaret Grant receives commissions, sales credit, or a markup or markdown on the sale of bonds and retail structured products such as certificates of deposit, constant maturity swaps (CMS), and CMS-linked notes.
CASH SWEEP & MONEY MARKET SWEEP
Cadaret Grant offers the Reich & Tang Liquid Insured Deposit Program through Pershing, LLC (“Pershing”). The Reich & Tang Liquid Insured Deposit Program is a bank deposit “sweep” program that can provide daily interest income and FDIC insurance on balances up to $2.5 million.
Cadaret Grant receives compensation from Pershing equal to a percentage of the average daily deposit balance. For additional information, please see the applicable disclosure booklet available from your Investment Representative. This compensation is retained by Cadaret Grant and is not shared with Investment Representatives.
The program provides FDIC insurance and payment rates based on the interest rate environment as well as based on total account balance. For accounts not interested in FDIC insurance, cash balances are invested in a money market fund. The money market mutual fund automatic cash sweep program sweeps uninvested cash daily into taxable or tax-exempt money market funds offered by Federated Investors. Cadaret Grant may receive compensation of up to 0.60% of the assets invested in the Federated Investors money market funds. This compensation is retained by Cadaret Grant and is not shared with Investment Representatives.
SECURITIES LENDING PROGRAM
Cadaret Grant offers Pershing’s fully paid Securities Lending program, which enable qualified investors to lend fully paid-for securities to Pershing. Pershing earns revenue from lending these securities and a portion of that revenue is shared clients, Cadaret Grant and Investment Advisor Representatives (IAR). If a client elects to participate in this program, the IAR will receive compensation from Pershing. The receipt of this extra compensation creates a conflict in certain advisor programs in which the IAR acts as the portfolio manager. The conflict surrounds whether this extra compensation would cause the IAR to hold a security in an account that would otherwise been liquidated but not for receipt of additional compensation. This conflict is mitigated by our requirement that investment decisions made by the IAR must be in the client’s best interests, as well as the fact that if an account holds these positions, the IAR’s compensation will increase nominally, but the security will also generate income for the account. Not all accounts or clients qualify for this program.
LOANADVANCE AND INVESTMENT CREDIT LINE PROGRAMS
Cadaret Grant offers Pershing’s LoanAdvance™ program which is a securities-based line-of-credit that can be used for most personal, consumer or business needs. In LoanAdvance, you pledge eligible securities in your advisory account as collateral to secure a non-purpose loan. You are charged a rate in interest that is a floating rate not to exceed 3 percentage points above the Prime Rate as published in The Wall Street Journal. The amount by which the interest rate is marked up over the negotiated Cadaret Grant Base Rate, if any, is shared by Pershing with Cadaret Grant and the Investment Advisor Representative. This results in additional compensation in connection with an advisory account. Trading is permissible in the advisory account that is pledged for the loan; however, the collateral must meet Pershing’s LoanAdvance maintenance requirement to support the loan. For financing needs of $1 million or more, clients can also participate in the BNY Mellon/Pershing Investment Credit Line Program (“ICL”). With an ICL, you can obtain a line-of credit secured by qualifying marketable securities and liquid assets in your advisory account in custody at Pershing for the following potential uses: business acquisition, start up or expansion; cash flow or working capital; estate planning and charitable strategies, home improvement, letters of credit, luxury purchases, medical, education, child care, elder care and other family obligations, real estate investments and tax obligations. An ICL may not be used to purchase or carry securities or fund an investment account. While an ICL can be a cost-effective alternative to liquidating appreciated or low cost basis assets to meet a liquidity need, clients should be aware that Cadaret Grant and the IAR have an incentive to recommend an ICL in lieu of liquidating assets in an account since Cadaret Grant will continue to earn an advisory fee on the collateral so long as the assets remain in the account.
ALTERNATIVE INVESTMENT PARTNERS
In addition to receiving commissions, Cadaret Grant receives a fixed fee and/or payments of up to 1.00% of customer assets invested in certain alternative investment products, including real estate investment trusts (REITs), business development companies (BDCs), and other closed-end funds. This compensation is not shared with financial professionals.
The following alternative investment sponsors currently participate in the Partners Program:
CIM f/k/a Cole Capital
UNIT INVESTMENT TRUST (UIT) PARTNERS
Cadaret Grant receives additional volume compensation based on total assets purchased from UIT sponsors over a given period of time as disclosed in the Unit Investment Trust’s prospectus. Certain UIT sponsors compensate Cadaret Grant for education seminars for Cadaret Grant financial professionals, customers, and prospective customers. This includes due diligence meetings, recreational activities, or other non-cash items. Also, marketing representatives of UIT sponsors, often referred to as “wholesalers,” work with financial professionals to promote their UITs. The volume concession rate does not exceed 0.035% per year.
The following UIT sponsors or brokers currently participate in the Partners Program:
THIRD-PARTY INVESTMENT ADVISERS
Cadaret Grant receives compensation from certain unaffiliated or third-party investment advisers to assist in paying for ongoing marketing and sales support activities including training, educational meetings, due diligence reviews, and day-to-day marketing and/or promotional activities. Current participating third-party advisers are:
Beacon Capital Management
Beaumont Capital Management
Morningstar Managed Portfolios
The compensation arrangements vary and are generally structured as a fixed dollar amount or as a stated percentage not exceeding 0.05% of sales and 0.03% on assets with the adviser.
A conflict of interest exists where Cadaret Grant receives such compensation because there is an incentive to recommend these third-party advisors over other investment opportunities to generate additional revenue for the firm. However, our financial professionals are not required to recommend any third-party advisor providing additional compensation, nor do they directly share in any of this compensation.
Our financial professionals receive additional compensation from product sponsors. However, such compensation is not tied to the sales of any products. Compensation includes such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with educational meetings or marketing or advertising initiatives, including services for identifying prospects. Product sponsors sometimes also pay for or reimburse Cadaret Grant for the costs associated with education or training events that are attended by our financial professionals and for Cadaret Grant-sponsored conferences and events. Cadaret Grant also receives reimbursement from product sponsors for technology-related costs associated with investment proposal tools they make available to our financial professionals for use with customers.
PERSHING CLEARING RELATIONSHIP
Pershing, LLC (“Pershing”) is the clearing firm for Cadaret Grant’s brokerage business. As a result of this business relationship, Pershing shares with Cadaret Grant a portion of certain commissions and fees customers pay to Pershing.
Pershing pays or shares with Cadaret Grant the following items:
While Cadaret Grant may share a portion of the revenue it receives from Pershing connected to a brokerage account with the financial professional for such account, Cadaret Grant does not share any revenue received from Pershing for investment advisory accounts with a financial professional.
OTHER FEE DISCLOSURES
Other fee disclosures related to our investment advisory business can be found in Cadaret Grant’s Form ADV, available at www.adviserinfo.sec.gov.
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