Disclosures

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 certain mutual fund families, insurance (fixed and variable product) providers, structured products, and alternative investment (REIT/BDC/MCLD/SP etc.) providers 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 providers, revenue sharing payments made in connection with programs that support our marketing and sales force education and training efforts (referred to here as “Strategic Partners Program”). These relationships bring additional compensation to Cadaret Grant, which is used to offset a variety of expenses, including but not limited to, marketing, training, educational presentations and other support.  This additional compensation may create a potential conflict of interest as it may influence the selection of investments Cadaret Grant and/or its Investment Representatives offer or recommend to investors.   This disclosure is intended to provide you with an overview of the various types of compensation and/or fees Cadaret Grant may receive.  We encourage you to review this information in the entirety and contact us with any questions. 

STRATEGIC PARTNERS PROGRAM

Strategic Partner Program participants (referred to as “Participating Sponsors” or “Strategic Partners”) are listed below. Participating Sponsors pay Cadaret Grant different amounts of revenue sharing and receive different levels of benefits for such payments. Some Participating Sponsors pay Cadaret Grant more than others, however, those fees are not shared with Investment Representatives. An Investment Representative’s compensation is the same regardless of whether the sale involves a Strategic Partner’s product.  In some cases, Participating Sponsors may pay additional marketing payments to Cadaret Grant to cover fees to attend conferences or reimbursement of expenses for workshops or seminars. The payments made under the Strategic Partners Program are calculated based upon gross sales or assets under management and vary by product provider. Payments may also be based on a flat fee arrangement.  Benefits Participating Sponsors receive may include Investment Representative contact lists, preferred placement on Cadaret Grant’s website, Cadaret Grant support of product training and ability to participate in Cadaret Grant conferences.

 MUTUAL FUND PARTICIPATING SPONSORS

In addition to receiving sales commissions and other types of compensation, Cadaret Grant receives asset-based and sales-based compensation from mutual fund Participating Sponsors.  Such payments vary by mutual fund sponsor.  Cadaret Grant may receive payments from mutual fund sponsors under the Strategic Partners Program of up to 0.20% annually on sales.  Alternatively, Cadaret Grant receives compensation on an annual basis of up to 0.0325% of customer assets from other Participating Sponsors.   The following is a list of mutual fund sponsors that participate in Cadaret Grant’s Strategic Partners Program:

• Alliance Bernstein
• American Funds
• Blackrock
• Columbia Threadneedle
• Franklin Templeton
• MFS
• Hartford
• Oppenheimer Funds
• Invesco
• Lord Abbett
• PIMCO
• Putnam

This list is subject to change.  Certain Strategic Partners only pay Marketing and Education Support. 

VARIABLE ANNUITY, FIXED ANNUITY, and INDEXED ANNUITY PARTICIPATING SPONSORS

In addition to receiving commissions, Cadaret Grant receives sales-based compensation from variable annuity, fixed annuity, and indexed annuity Participating Sponsors. Cadaret Grant receives compensation on an annual basis of up to 0.50% on sales of these products.

The following is a list of variable annuity, fixed annuity, and indexed annuity sponsors that participate in Cadaret Grant’s Strategic Partners Program:

• AIG
• Allianz
• American National
• AXA
• Brighthouse
• Delaware Life Insurance Company
• First Symetra Life Insurance Company of NY
• Jackson
• Lincoln
• Nationwide
• Pacific Life
• Prudential
• Security Benefit
• Symetra Life Insurance Company
• Transamerica

This list is subject to change.  Certain Strategic Partners only pay Marketing and Education Support. 

ALTERNATIVE INVESTMENT PARTICIPATING SPONSORS

In addition to receiving commissions, Cadaret Grant receives payments of up to 1.00% of sales on customer assets invested in alternative investment products, including but not limited to real estate investment trusts, business development companies and other ’40 Act funds. This compensation is not shared with Investment Representatives.  

The following alternative investment sponsors participate in Cadaret Grant’s Strategic Partners Program:

• CIM f/k/a Cole Capital                                               
• Griffin Capital
• Hines Securities

This list is subject to change.  Certain Strategic Partners only pay Marketing and Education Support.

UNIT INVESTMENT TRUSTS (UITs)

 Cadaret Grant receives additional volume compensation based on total assets purchased from the sponsor over a given period of time as disclosed in the Unit Investment Trust’s prospectus. UIT sponsors may compensate Cadaret Grant for training and education seminars for Cadaret Grant associates, Investment Representatives, clients and potential clients. This may include due diligence meetings, recreational activities or other non-cash items. Also, marketing representatives of UIT sponsors, often referred to as “wholesalers”, work with Investment Representatives and their managers to promote their UITs.  The volume concession rate does not exceed .035% per year. The following is a list of UIT companies that participate in Cadaret Grant’s Strategic Partners Program:

• First Trust

This list is subject to change.  Certain Strategic Partners only pay Marketing and Education Support.  We may receive volume concessions from other UIT companies when certain sales hurdles are met.

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.

THIRD-PARTY INVESTMENT ADVISORS

Cadaret Grant receives compensation from certain Third-Party Advisors to assist in paying for ongoing marketing and sales support activities including, but not limited to, training, educational meetings, due diligence reviews, and day-to-day marketing and/or promotional activities. Not all Third-Party Advisors pay such compensation.  Participating Third Party Advisors may change over time. Current participating Third-Party Advisors are: 

• Advisors Capital Management
• AssetMark
• Morningstar
• SEI

The compensation arrangements vary, and may generally be structured as follows:

• A stated percentage of gross sales generally not exceeding .050% of net sales with the Third-Party Advisor.
• A stated percentage of assets under management generally not exceeding .03% of assets under management with the Third-Party Advisor.

A potential conflict of interest may exist where Cadaret Grant receives such compensation because there may be an incentive to recommend these Third-Party Advisors over other investment opportunities in order to generate additional revenue for the firm. However, our Investment Advisor Representatives are not required to recommend any Third-Party Advisor providing additional compensation, nor do they directly share in any of this compensation.

Certain Strategic Partners only pay Marketing and Education Support. 

 OTHER COMPENSATION

Cadaret Grant Representatives may receive additional compensation from product sponsors however; such compensation is not tied to the sales of any products. Compensation may include 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 may also pay for, or reimburse Cadaret Grant for the costs associated with education or training events that may be attended by Cadaret Grant advisors 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 it makes available to its Cadaret Grant Representatives for use with customers.

PERSHING CLEARING RELATIONSHIP

Pershing, LLC (“Pershing”) is the clearing firm for Cadaret Grant brokerage business. Due to this business relationship, Pershing may share with Cadaret Grant a portion of the commissions and fees you may pay to Pershing. The following is a brief description of some of the revenue items received from Pershing.

Pershing receives revenue from money market funds and deposit sweeps, and shares that revenue with Cadaret Grant for money market funds/deposit sweeps made available to you for cash sweeps in your brokerage account. Cadaret Grant Representatives do not receive any part of this revenue.

Pershing receives shareholder servicing fees from certain mutual fund sponsors as part of their FundVest NTF (No Transaction Fee) program, and shares a portion of these fees with Cadaret Grant and does not charge Cadaret Grant a ticket charge. Cadaret Grant Investment Representatives do not receive any part of this revenue.

Pershing charges brokerage fees including account transfer fees, IRA custodial and termination fees, paper confirm statement fees, and inactive (custodial) account fees. Portions of these fees may be shared with Cadaret Grant. Representatives do not receive any part of this revenue. 

Additional Pershing fees that may be shared with Cadaret Grant include but is are limited to the following: retirement maintenance fees, margin fees, inactive accounts fees, and recruiting fees.

OTHER FEE DISCLOSURES

Other fee disclosures related to our investment advisory business can be found in Cadaret Grant’s Form ADV, available at www.cadaretgrant.com.