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Sections:

Customer Relationship Summary
Regulation Best Interest Disclosure



Customer Relationship Summary

Helping you make an informed decision




Introduction

Linden Thomas and Company, LLC (“LTCo”) has three affiliated entities.

  • Linden Thomas and Company Securities, LLC, a registered broker-dealer with the Financial Industry Regulatory Authority (“FINRA”) & the Securities Exchange Commission (“SEC”), and
  • Linden Thomas Advisory Services, LLC, a registered investment adviser with the SEC.
  • Indexperts, LLC, a registered investment adviser with the SEC.

Securities services are offered through Linden Thomas and Company Securities, LLC; member FINRA and Securities Investor Protection Corporation (“SIPC”). Advisory services are offered through Linden Thomas Advisory Services, LLC.

Brokerage and investment advisory services fees differ, and it is important to understand the differences.

Free and simple tools are available for you to use at Investor.gov/CRS, a website maintained by the SEC. These tools can provide you with educational materials about broker-dealers, investment advisers, and investing.

This relationship summary provides information that helps you make an informed decision about whether or not to invest with us and will answer the following questions:

  • What investment services and advice can you provide me?
  • What fees will I pay?
  • What are your legal obligations to me when providing recommendations as my broker-dealer, or when acting as my investment adviser? How else does the firm make money and what conflicts of interest do you have?
  • How do your financial professionals make money?
  • Do you or your financial professionals have legal or disciplinary history?
  • Where can I find additional information?


Terms To Know

  • A broker-dealer is a firm that acts as an intermediary between buyers and sellers of securities for which they will usually receive a commission and may purchase or sell those securities in/out of their own account.

  • An investment adviser is generally any person or group that provides investment advice or conducts securities analysis in exchange for a fee.



What investment services and advice can you provide me?

Brokerage Services

LTCo offers brokerage services and investment advisory services, to retail investors. Within a brokerage account, clients may invest in equities, fixed income (bonds), options, and mutual funds. Within an advisory account, clients may access the proprietary index funds managed by LTCo, as well as account management by 3rd party money managers.

Additional detailed information about these services is available at www.lindenthomas.com, and on the Form ADV, Part 2A brochure available upon request.

Linden Thomas & Company Securities, LLC offers brokerage services to retail investors, including buying and selling securities, and recommendations to retail investors.

Linden Thomas & Company Securities, LLC provides ongoing account and investment monitoring.

Investment Advisory Services

Linden Thomas Advisory Services, LLC offers investment advisory services to retail investors, including financial planning and wrap fee programs.

Linden Thomas Advisory Services, LLC provides ongoing monitoring.

Additional detailed information about advisory services and programs is available on the Firm’s website.



Conversation Corner

Questions you might wish to ask when considering our services:

  • Given my financial situation, should I choose an investment advisory service? Should I choose a brokerage service? Should I choose both types of services? Why or why not?

  • How will you choose investments to recommend to me?

  • What is your relevant experience, including your licenses, education, and other qualifications? What do these qualifications mean?


What fees will I pay?

Fees are different for Brokerage and Advisory accounts and services.

You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.”

Brokerage Services Fees

These are transaction-based fees investors pay every time they buy or sell an investment. This fee, commonly referred to as a commission, is based on the specific transaction and not the value of your account. This fee can be charged in many ways, including as a separate and distinct fee, included as a part of the purchase of the security, or in the case of mutual funds as an embedded cost of the fund, which may include a redemption fee. The Firm may charge clients additional fees, disclosed at account opening and in a mailing on an annual basis. From a cost perspective it may be beneficial to a client to incur a transaction-based fee if they do not trade often or if they plan to buy and hold investment for a long period of time.

Investment Advisory Services

Fees and costs you may incur for investment advisory services, and/or financial planning services are provided as follows:

The Firm may charge its customers in one or more of the following manners: a percentage of assets under management, or an hourly or fixed fee for financial planning.

  • A fee calculated on assets under management typically applies to account management Fees vary depending on the program and the total assets under management. Fees for asset management programs are generally calculated and charged quarterly in advance based on period ending balance of assets under management at the end of the preceding quarter. Fees for partial quarters are prorated based on the number of days assets are under management. Fees are generally deducted directly from client accounts, but clients may elect to alternatively pay fees by check.

 

  • Hourly and/or fixed fees typically apply to financial planning services, which may include estate planning, retirement planning, tax planning, education funding, risk management, and employee benefits planning. Fees charged for financial planning services may be charged in advance or in arrears depending on the service provided. Fees are negotiated in advance, and generally range from .30% to 1.00% depending on the level of complexity of the engagement. Fee rates are based on actual services provided rather than being based on the level of assets managed as detailed above for investment management services. In some cases, fees may be deducted directly from client accounts, but clients generally are billed directly on a quarterly basis

Other Fees and Costs?

There may be additional fees and costs related to your brokerage or investment advisory services and investments in addition to the firm’s principal fees and costs disclosed above that you will pay directly or indirectly. Examples of these categories of the most common fees and costs applicable to you may include but are not limited to the following: custodian fees, account maintenance fees, fees related to mutual funds, and other transactional fees and product-level fees.

The Firm offers wrap-fee programs, and as such there may be asset-based fees associated with the wrap fee program which may include transaction costs and fees to a broker-dealer or bank that has custody of these assets. This may result in a higher than typical asset based advisory fee. 

The Firm does not charge asset-based fees that vary with the size of the account. This prevents a potential conflict of interest where an investment adviser may encourage a customer to consolidate their assets so as to achieve a lower fee rate. 

For additional information please view the Firm’s Form ADV available at: 

Linden Thomas Advisory Services, LLC: https://adviserinfo.sec.gov/firm/summary/288557 

Indexperts, LLC: https://adviserinfo.sec.gov/firm/summary/314858 



Conversation Corner

Questions you might wish to ask when considering our services:

  • Help me understand how these fees and costs might affect my investments.

  • If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?

  • How might your conflicts of interest affect me, and how will you address them?


What are your legal obligations to me when providing recommendations as my broker-dealer or when acting as my investment adviser? How else does the firm make money and what conflicts of interest do you have?

Standard of Conduct

When we provide you with a recommendation as your broker-dealer or act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the recommendations and investment advice we provide you. Here are some examples to help you understand what this means.

Examples of Ways We Make Money and Conflicts of Interest

Proprietary Products: Index mutual fund investments are issued, sponsored, and managed by LTCo.

Revenue Sharing: 3rd Party money managers of investment advisory accounts may share revenue earned on those investments.

For additional information about potential conflicts of interest, please see:

Form ADV: 

Linden Thomas Advisory Services, LLC: https://adviserinfo.sec.gov/firm/summary/288557 

Indexperts, LLC: https://adviserinfo.sec.gov/firm/summary/314858 

Regulation Best Interest Disclosure: available upon request 



Conversation Corner

Questions you might wish to ask when considering our services:

  • How might your conflicts of interest affect me, and how will you address them?


How do your financial professionals make money?

The Firm’s financial professionals are compensated by commission in brokerage accounts and by management fees in advisory accounts. Financial professionals are not compensated based on factors such as the amount of client assets they service, the time and complexity required to meet a client’s needs, the product sold, or revenue the firm earns from the financial professional’s advisory services or recommendations.

For additional detailed information about these fees, please refer to advisory fees on the Firm’s Form ADV (URL provided below) and brokerage fees provided within your new acct documents.

Do you or financial professionals have legal or disciplinary history?

Yes - please refer to https://brokercheck.finra.org/ which is a free tool to research the background and experience of financial brokers, advisers and firms. 

Where can I find additional information?

You can always ask your financial advisor for more information and request a copy of this relationship summary at 704-554-8150 / toll free at 877-554-8150 / fax 704-554-8350 

URL to Form ADV: 

Linden Thomas Advisory Services, LLC: https://adviserinfo.sec.gov/firm/summary/288557 

Indexperts, LLC: https://adviserinfo.sec.gov/firm/summary/314858 

Form CRS (this document), Regulation Best Interest Disclosure, Legal Disclosure, Margin Disclosure, and Cash Sweep Program Disclosure are either included within your account opening documents or are available upon your request. 



Conversation Corner

Questions you might wish to ask when considering our services:

  • As a financial professional, do you have any disciplinary history? For what type of conduct? 

  • Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Whom can I talk to if I have concerns about how this person is treating me? 


Regulation Best Interest Disclosure




This guide summarizes important information concerning the scope and terms of the brokerage services we offer and details the material conflicts of interest that arise through our delivery of brokerage services to you. We encourage you to review this information carefully, along with any applicable account agreement(s) and disclosure documentation you may receive from us.

As you review this information, we would like to remind you that we are registered with the U.S. Securities and Exchange Commission (SEC) as a broker-dealer and an investment adviser, providing both brokerage services and investment advisory services. Our brokerage services are the primary focus of this guide. For more information on our investment advisory services and how they differ from brokerage, please review the Customer Relationship Summary (or Form CRS) available upon request, and our Form ADV which can be located at

Linden Thomas Advisory Services, LLC: https://adviserinfo.sec.gov/firm/summary/288557 

Indexperts, LLC: https://adviserinfo.sec.gov/firm/summary/314858 

Our Form CRS contains important information about the types of services we offer, both brokerage and investment advisory, along with general information related to compensation, conflicts of interest, disciplinary action and other reportable legal information. 

Please carefully review and consider the information in each section below.

Brokerage Services

Brokerage Service Models and Products

Brokerage Fees and Our Compensation

Conflicts of Interest

Additional Resources


Brokerage Services

When you establish a brokerage account with us, you have the ability to buy, sell and hold investments within your account. The primary service we provide is our trading capability. We execute purchases and sales on your behalf, and as directed by you. In a brokerage services relationship, we can trade with you for your own account, for an affiliate or for another client, and we may earn compensation (i.e., commissions, mark-up/mark-down) on those trades. The capacity in which we act is disclosed on your trade confirmation (i.e., as agent or as principal). However, we are not required to communicate it in advance, obtain your consent, or inform you of any profit earned on trades. It is important to note that we do not receive compensation unless a brokerage transaction occurs.

Cash Brokerage and Margin Brokerage Accounts

We provide brokerage services through either a cash brokerage account or margin brokerage account, based on your eligibility and selection. In a cash brokerage account, you must pay for your purchases in full at the time of purchase. In a margin brokerage account, you must eventually pay for your purchases in full, but you may borrow part of the purchase price from our clearing firm, First Clearing1. This is generally referred to as a “margin loan.” The portion of the purchase price that is loaned to you is secured by the securities in your account, also referred to as “collateral.” You will incur interest costs which we may share in as a result of your margin activity. While many securities are eligible to be used as collateral for a margin loan, some assets are not available for margin collateral purposes.

Given that a margin-enabled brokerage account has specific eligibility requirements, unique costs, and governing regulatory requirements, our default brokerage option is our cash brokerage account. You must execute a separate margin agreement before engaging in margin brokerage activity. Included with your margin agreement is a copy of the Margin Disclosure Statement. This statement contains important information you should understand and consider before establishing a margin brokerage relationship with us. For more information on our margin brokerage services, contact a Registered Representative (RR) or refer to our Margin Disclosure Statement available in your account opening documents or at your request.

1 First Clearing is a trade name used by Wells Fargo Clearing Services, LLC. 

Brokerage Account Types

We offer many different brokerage account types including individual and joint accounts, custodial accounts, Delivery Versus Payment (DVP) accounts, estate and trust accounts, partnership accounts, individual retirement accounts and other types of retirement accounts as outlined in our account agreement(s). You should refer to our account agreement(s) for more information concerning available account types or speak with a RR.

Incidental Brokerage Services, Recommendations and Account Monitoring

Within your brokerage account, we may also provide other incidental services such as research reports, and recommendations to buy, sell, or hold assets. When we make a securities recommendation, investment strategy recommendation or recommendation to rollover assets from your Qualified Retirement Plan (QRP) to an Individual Retirement Account (IRA), the recommendation is made in our capacity as a broker-dealer unless otherwise stated at the time of the recommendation. Any such statement will be made orally to you. Moreover, when we act in a brokerage capacity, we do not agree to enter into a fiduciary relationship with you.

It is important for you to understand that when our RRs make a brokerage recommendation to you, we are obligated to ensure the recommendation is in your best interest, considering reasonably available alternatives, and based on your stated investment objective, risk tolerance, liquidity needs, time horizon, financial needs, tax status, and other financial information you provide us. You may accept or reject any recommendation. It is also your responsibility to monitor the investments in your brokerage account, and we encourage you to do so regularly. We do not commit to provide on-going monitoring of your brokerage account. If you prefer on-going monitoring of your account or investments, you should speak with a RR about whether an advisory services relationship is more appropriate for you.

Please also consider that from time to time we may provide you with additional information and resources to assist you with managing your brokerage account. This may include but is not limited to educational resources, sales and marketing materials, performance reports, asset allocation guidance, and/or periodic brokerage account reviews. When we offer these services and information, we do so as a courtesy to you. These activities are not designed to monitor specific investment holdings in your brokerage account, they do not contain specific investment recommendations about investment holdings, and you should not consider them a recommendation to trade or hold any particular securities in your brokerage account. Upon your request, we will review such information and reports with you and may provide you with investment recommendations, but we are not under a specific obligation to do so. We act as a broker, dealer, or an associated person of a broker-dealer with respect to any recommendations made at the time of a periodic brokerage account review.

Clearing Services

We have entered into an agreement with First Clearing (also referred to herein as “Clearing Firm”) to carry your account and provide certain back office functions. We and First Clearing share responsibilities with respect to your account as set forth in the Designation of Responsibilities that was delivered to you upon opening of your account. Please refer to the Designation of Responsibilities for more information on how such responsibilities have been allocated between us.

Understanding Risk

It is important for you to understand that all investment recommendations and activities involve risk, including the risk that you may lose your entire principal. Further, some investments involve more risk than other investments. Higher-Risk investments may have the potential for higher returns but also for greater losses. The higher your “risk tolerance,” meaning the amount of risk or loss you are willing and able to accept in order to achieve your investment goals, the more you may decide to invest in higher-risk investments offering the potential for greater returns. We align risk tolerances with investment needs to offer you different investment objectives from which to choose (see below). You should select the investment objective and risk tolerance best aligned with your brokerage account goals and needs.

Investment goals typically have different time horizons and different income and growth objectives. Generally, investment goals are on a spectrum, with “Income” investors typically holding the smallest percentage of higher-risk investments, followed by “Growth and Income” investors holding some higher-risk investments, and finally “Growth” investors holding a significant portion of their portfolio in higher-risk investments. Risk tolerance also varies, and we measure it on a continuum that increases from “Conservative” to “Moderate” to “Aggressive,” and finally “Trading and Speculation.” See below for details.

Generally Associated Risk Tolerance

Income Investment Objective

Typical Investment Objective Description - Income portfolios emphasize current income with minimal consideration for capital appreciation and usually have less exposure to more volatile growth assets.

    • Conservative - Conservative Income investors generally assume lower risk, but may still experience losses or have lower expected income returns.
    • Moderate - Moderate Income investors are willing to accept a modest level of risk that may result in increased losses in exchange for the potential to receive modest income returns.
    • Aggressive - Aggressive Income investors seek a higher level of returns and are willing to accept a higher level of risk that may results in greater losses.

Growth and Income Investment Objective

Typical Investment Objective Description - Growth and Income portfolios emphasize a blend of current income and capital appreciation and usually have some exposure to more volatile growth assets.

    • Conservative - Conservative Growth and Income investors generally assume a lower amount of risk, but may still experience losses or have lower expected returns.
    • Moderate - Moderate Growth and Income investors are willing to accept a modest level of risk that may result in increased losses in exchange for the potential to receive modest returns. 
    • Aggressive - Aggressive Growth and Income investors seek a higher level of returns and are willing to accept a higher of risk that may result in greater losses.

Growth Investment Objective

Typical Investment Objective Description - Growth portfolios emphasize capital appreciation with minimal consideration for current income and usually have significant exposure to more volatile growth assets.

    • Conservative - Conservative Growth and Income investors generally assume a lower amount of risk, but may still experience losses or have lower expected returns.
    • Moderate - Moderate Growth investors are willing to accept a modest level of risk that may result in significant losses in exchange for the potential to receive higher returns. 
    • Aggressive - Aggressive Growth investors seek a higher level of returns and are willing to accept a high level of risk that may result in more significant losses.

Trading and Speculation

Trading and Speculation investors seek out a maximum return through a broad range of investment strategies which generally involve a high level of risk, including the potential for unlimited loss of investment capital. 

Our recommendations are based in part on your risk tolerance and investment objective as outlined above. We encourage you to carefully consider your investment objective and risk tolerance before investing.

Account Minimums and Activity Requirements

There is no minimum initial account balance required to open a brokerage account with us. However, if you either fail to fund your account or do not return account opening documents as required, your account will be closed. In addition, some types of brokerage accounts have minimum account activity requirements and/or minimum on-going balance requirements that must be maintained, or your brokerage account may either be closed or assessed a fee for inactivity, of which we may share. These requirements are detailed in the account agreement(s) you receive when you open your brokerage account.

You should also understand that our RRs may establish their own minimum account balance requirements for the brokerage accounts they service. For example, a dedicated RR may choose to service only those brokerage account clients who satisfy account-specific or total household asset conditions. Minimum asset requirements are disclosed to you orally by your RR. 

Brokerage Services Models and Products

The Firm is a full-service brokerage model, offering investments including, but not limited to equities, fixed income, mutual funds and options. The Firm also offers a direct trading option at a discounted rate, without the assistance of a RR, if so desired by a client.

Brokerage Fees and Our Compensation

It is important to consider that while a brokerage relationship can be a cost-effective way of investing your assets, it is not for everyone given the fees and costs involved.

Transaction-Based Fees

You will pay transaction-based fees for trades you decide to enter into, such as buying and selling stocks, bonds, Exchange Traded Products (ETPs), mutual funds, exercising options and other investment purchases and sale. These transaction-based fees are generally referred to as a “commission,” “mark-up/mark-down,” “sales load,” or a “sales charge.” Transaction-Based fees are based on a host of factors, including, but not limited to:

  • Underlying product selection
  • Your brokerage service model and account type
  • Size of your transaction and/or overall value of your account
  • Frequency of your trade activity
  • Available discounts and/or fee waivers

Account and Service Fees

You will pay fees for various operational services provided to you through your brokerage account. These fees are set at least annually and communicated to you through information included in your account statement and other notifications. These fees do not apply to all account types and may be waived under certain conditions.

You should understand that based on the brokerage service model you choose, the same or similar products, accounts and services may vary in the fees and costs charged to you.

How We Are Compensated

We receive direct and indirect compensation in connection with your accounts. Direct compensation is taken directly from the affected account. Indirect compensation is compensation paid in ways other than directly from the account and may impact the value of the associated investments in your account. The sections below describe the compensation that we receive in connection with various investments that may be available to you. In many cases, the descriptions that follow refer to a prospectus or offering documents.

Debt Securities

For debt securities, including preferred securities and CDs, we may apply a charge (i.e., mark-up/mark-down) based on the amount of your secondary transaction. This would be done on a riskless and simultaneous basis and the mark-up or mark-down would be disclosed on your customer confirmation.

Mutual Funds

We currently offer thousands of mutual funds varying in share class structure and investment style. If you invest in mutual funds, we generally receive direct and indirect compensation in connection with such mutual fund investments, as described below.

12b-1/Shareholder Service Fees

Annual 12b-1 fees, also known as trails, are paid to us by the fund out of fund assets under a distribution and servicing arrangement to cover distribution expenses and sometimes shareholder service expenses that we may provide on the fund’s behalf. Shareholder servicing fees are paid to respond to investor inquiries and provide investors with information about their investments. These fees are asset-based fees charged by the fund family. These fees vary and are determined by the product company. These fees may be passed on to us and may in turn be passed on to your RR as a commission. Additional information about 12b-1 and shareholder servicing fees can be found in the individual fund’s prospectus. The amount of these fees paid indirectly by you affects the return on your investment.

Front-End Sales Charge Fees or Contingent Deferred Sales Charges (CDSC) 

Front-End sales charge fees may be charged and paid to us, including your RR, when you purchase a fund. The front-end sales charge is deducted from the initial investment on certain share classes. This charge varies and is determined by the product company. Some purchases may qualify for a reduced front-end sales charge due to breakpoint discounts based on the amount of the transaction and rights of accumulation or letters of intent. In addition, some purchases may qualify for a sales charge waiver based on the type of account, and/or certain qualifications within the account. You should contact your RR if you believe you are eligible for sales charge waivers.

CDSC is a charge you pay upon withdrawal of money from a fund prior to the end of the fund’s CDSC period. CDSC charges vary and are determined by the product company. CDSC periods typically range from zero to seven years. This charge typically exists only on share classes that do not have a front-end sales charge. It is sometimes referred to as the back-end load. CDSCs are not charged when you purchase a fund. The fee charged will depend on the share class purchased by the investor. A CDSC is not passed on to your RR. You can find a description of the amount and payment frequency of all fees and expenses charged and paid by the fund in the fund’s prospectus. Fees and expenses disclosed in the fund’s prospectus are charged against the investment values of the fund. Please note that 12b-1s and similar fees or compensation received in connection with our affiliated funds are not received, or are rebated, on ERISA assets held in Advisory Program accounts but not in retail brokerage accounts.

Cash Sweep Program/Bank Deposit Sweep/Other Float Compensation 

Cash Sweep Program Feature

Our brokerage services include a Cash Sweep Program feature. This program permits you to earn a return on uninvested cash balances in your brokerage account by allowing cash balances to be automatically “swept” into a “Cash Sweep Vehicle,” until such balances are otherwise required to satisfy obligations arising in your account. These Cash Sweep Vehicles include interest-bearing deposit accounts, and if permissible, money market mutual funds or such other sweep arrangements made available to you. You will receive additional information concerning the Cash Sweep Program in your account agreement(s). More information about the Cash Sweep Program can be found in the Cash Sweep Program Disclosure Statement at https://www.wellsfargoclearingservicesllc.com/bw/fccs/forms/568205.pdf  which we provided to you when you opened your account. Please review that full Disclosure Statement carefully.

The available sweep vehicles currently consist of

  1. interest-bearing deposit accounts at First Clearing’s affiliated and unaffiliated banks in First Clearing’s Expanded Bank Deposit Sweep program, 
  2. interest-bearing deposit accounts at two First Clearing affiliated banks in First Clearing’s Standard Bank Deposit Sweep program, and
  3. one or more First Clearing affiliated and non-affiliated Money Market Mutual Funds.

Eligibility for each available sweep vehicle is determined by account type.

The Program Fees and the Platform Fee charged on account values will apply to uninvested cash balances and balances in the Cash Sweep Program, to the extent permitted by law. The fees for the Program (including the Program and Platform Fee) will exceed the return you earn on uninvested cash and, in most instances, on the vehicle in the Cash Sweep Program.

When a First Clearing affiliated Money Market Mutual Fund is used, First Clearing or their affiliates may serve as adviser, sub-adviser, distributor, or administrator to the fund and receive compensation for the services provided. Additional information about these funds is found in their prospectuses. First Clearing and their affiliates benefit financially from cash balances held in the Expanded and Standard Bank Deposit Sweeps.

In addition to the fees applicable to the Program (including the Program and Platform Fee), as a shareholder of a money market mutual fund or closed-end fund, you will bear a proportionate share of the fund's expenses, including investment management fees that are paid to the fund's investment adviser, who may be an affiliate of First Clearing.

First Clearing may earn fees from their possession and temporary investment of cash balances in your account(s) before they are "swept" into a money market fund, or the Expanded or Standard Bank Deposit Sweep. A portion of these fees may be paid to us.

You may elect not to participate in the Cash Sweep Program. The Cash Sweep Program should not be viewed as a long-term investment option. It is your responsibility to monitor your balances in the Cash Sweep Program and determine whether you prefer to invest cash balances in products offered outside the Cash Sweep Program.

Training and Education

We do not receive any training compensation from product sponsors or our Clearing Firm.

Operational Fees

The Clearing Firm receives compensation for various operational services provided to you through a brokerage account. Our fee schedule for these services can be found in your account documentation or your confirmations.

Trade Corrections

The error account will only be used to correct errors and will not be used as a trading account. This means immediately after an error is detected, a closing transaction should be entered. Positions will not be held in the account in an effort to affect a better execution, to limit losses, or to generate profits, either for the Company or for a customer. No open positions are to be kept in the error account overnight without approval of the Clearing Firm’s Designated Principal or their designee.

When a transaction is required to be placed in the error account, a written explanation is required to be provided by the individual committing the error. Included in this explanation should be transaction information (trade date, time of order entry, security name, buy/sell/sell short, quantity, price of order, name and account number of the customer on whose instructions the order was placed) rationale and cause. The transaction and the memorandum must be reviewed and approved in writing by the Clearing Firm’s Designated Principal or their designee. Evidence of the supervisory review must be in writing and will be retained with the Company’s records for six years, two years in a readily accessible location.

It is the Company’s policy that no client or associated person should benefit from errors for which they are responsible. All profits resulting from their errors will be removed from their accounts, and all losses resulting from their errors will be charged to their accounts.

Compensation for Termination of Services

Other than any contingent deferred sales charge for a fund (as described under the Mutual Funds section above, if applicable), IRA termination fees (when applicable), and account transfer fees, the firm would not receive any additional compensation in connection with the termination of its services. If you have questions or need additional copies, contact your RR.

Brokerage - Excluded Advisory Assets

As described above, our brokerage services differ from our advisory services. However, in some instances we may allow an advisory client to trade what are referred to as “excluded assets” within their advisory services account. Excluded assets are not subject to our advisory program fees. Instead of our advisory fees, these excluded assets are subject to our standard brokerage charges when traded.

Conflicts of Interest

Conflicts of interest exist when we provide brokerage services to you. A conflict of interest is a situation in which we engage in a transaction or activity where our interest is materially adverse to your interest. The mere presence of a conflict of interest does not imply that harm to your interests will occur, but it is important that we acknowledge the presence of conflicts. Moreover, our regulatory obligations require that we establish, maintain, and enforce written policies and procedures reasonably designed to address conflicts of interest associated with our recommendations to you.

Our conflicts of interest are typically the result of compensation structures and other financial arrangements between us, our RRs, our clients and third parties. We offer a broad range of investment services and products and we receive various forms of compensation from our clients, affiliated and non-affiliated product providers and money managers, and other third parties as described above. Securities rules allow for us, our RRs, and our affiliates to earn compensation when we provide brokerage services to you. However, the compensation that we and our RR receive from you varies based upon the product or service you purchase, which creates a financial incentive to recommend investment products and services that generate greater compensation to us.

We are committed to taking appropriate steps to identify, mitigate and avoid conflicts of interest to ensure we act in your best interest when providing brokerage recommendations to you. Below you will find additional information related to our conflicts of interest. This information is not intended to be an all-inclusive list of our conflicts, but generally describes those conflicts that are material to your brokerage relationship. In addition to this disclosure, conflicts of interest are disclosed to you in your account agreement(s) and disclosure documents, our product guides and other information we make available to you.

Compensation We Receive From Clients

Transaction-Based Conflicts

In your brokerage account you pay certain fees (commissions and sales charges) in connection with the buying and selling of each investment product, including mutual funds, equity securities, and bonds. Where these fees apply, the more transactions you enter into, the more compensation that we and your RR receive. This compensation creates an incentive for us to recommend that you buy and sell, rather than hold, these investments. We also have an incentive to recommend that you purchase investment products that carry higher fees, instead of products that carry lower fees or no fees at all.

Markups and Markdowns for Principal Transactions

The firm will not hold any investments in its inventory as a principal for the intent of reselling to its clients. We may enter the marketplace to purchase the security into our own account and then concurrently sell you the security or purchase the security from you and then concurrently sell it to the marketplace. This type of transaction will only be done in order to fulfill a customer’s order. This is referred to as a “riskless principal” transaction. Riskless principal transactions are generally used to buy and sell fixed income securities or preferred stock. We impose a mark-up (increase) or mark-down (decrease) in the price of security in a riskless principal transaction.

Our compensation is based upon the difference between the price you pay for securities purchased from us and the price we sell such securities to you over the prevailing market price (mark-up), or the difference between the price you sell securities to us and the price we purchase such securities from you over the prevailing market price (mark-down). We maintain policies and procedures reasonably designed to help ensure compliance with the mark-up and mark-down industry rules.

Account Maintenance and Other Administrative Fees

For the services we provide or make available to you with respect to your brokerage account, we charge certain account maintenance and other administrative fees, including transfer, wire, or other miscellaneous fees, as described in the fee schedule provided to you on an annual basis. The higher the fees we charge, the more we are compensated.

Compensation We Receive From Third Parties

Third-Party payments we receive may be based on new sales of investment products, creating an incentive for us to recommend you buy and sell, rather than hold, investments. In other cases, these payments are made on an ongoing basis as a percentage of invested assets, creating an incentive for us to recommend that you buy and hold investments (or continue to invest through a third-party manager or adviser).

The total amount of payments we receive varies from product to product, and varies with respect to the third-party investment management products we recommend. It also varies from the compensation we receive in connection with other products and services we may make available to you, including advisory services. We have an incentive to recommend investment products and services that generate greater payments to us. This compensation generally represents an expense embedded in the investment products and services that is borne by investors, even where it is not paid by the Product Sponsor and not directly from the investment product or other fees you pay. The types of third-party compensation we receive include:

  • Trail Compensation. Ongoing compensation from Product Sponsors may be received by us and shared with our RRs. This compensation (commonly known as trails, service fees or Rule 12b-1 fees in the case of mutual funds) is typically paid from the assets of the investment product under a distribution or servicing arrangement and is calculated as an annual percentage of invested assets. The amount of this compensation varies from product to product. We have an incentive to recommend that you purchase and hold interests in products that pay us higher trails.

Additional Compensation from Product Sponsors and Other Third Parties

We and our RRs, associates, employees, and agents do not receive additional compensation from Product Sponsors and other third parties.

Note: If in the future we opt to accept such compensation, the amount of these payments will not be dependent or related to the level of assets you or any other of our clients invest in or with the Product Sponsor.

Product Share Classes

Some Product Sponsors offer multiple structures of the same product (i.e., mutual fund share classes) with each option having a unique expense structure, and some having lower costs to you as compared to others. We are incentivized to make available those share classes or other product structures that will generate the highest compensation to us.

Compensation Related to Proprietary Products

Brokerage recommendations can include a recommendation to invest in a product or service that is managed, issued or sponsored by us or our affiliates. We and our affiliates will receive additional compensation or economic benefits from investments by you in such products, including, but not limited to, management credits, service fees and similar revenue sharing arrangements. The compensation related to these may be greater than similar products provided by third parties. Thus, we have an incentive to recommend investments in proprietary/affiliated products.

Compensation Related to Our Affiliates

Our broker-dealer does not receive compensation from its affiliates. It only shares expenses with such entities.

Compensation Received by RRs

RRs are compensated in a variety of ways based on the percentage of revenue generated from sales of products and services to clients and/or total assets under advisement, including brokerage account activity. This compensation may vary by the product or service associated with a brokerage recommendation. In addition to upfront-transaction based compensation, some products feature on-going residual or “trail” payments. Thus, RRs are incentivized to recommend products that have higher fees as well as those with on-going payments.

Typically, a RR’s payout schedule (periodically adjusted by us at our discretion) increases with production and asset levels. The same payout schedule is reduced when RRs discount certain client fees and commissions, or client relationship asset levels are below minimums established by us from time to time. RRs also may be eligible for annual or ongoing bonuses and deferred compensation awards based upon a variety of factors that may include reaching certain production levels, tenure with the firm, client product mix, asset gathering, referrals to affiliates or other targets, as well as compliance with our policies and procedures and meeting best business practices.

As a result, RRs have an incentive to provide brokerage recommendations that result in selling more investment products and services, as well as investment products and services that carry higher fees. RRs also have an incentive to provide brokerage recommendations to gather more assets under management and to increase brokerage trading activity, and to reduce the amount of discounts available to you.

RRs have an incentive to recommend you rollover assets from a Qualified Retirement Plan (QRP) to a brokerage Individual Retirement Account (IRA) because of the compensation they will receive. We maintain policies and procedures designed to ensure that rollover recommendations are in your best interest.

Brokerage accounts, unlike advisory accounts, do not feature an on-going fee based on assets under management. RRs are incentivized to recommend you transition your brokerage services account to an advisory account to generate on-going revenue where your brokerage account has minimal activity. Further, RRs are incentivized to recommend you transition your brokerage account to an advisory account after you have already placed purchases resulting in commissions and/or other transaction-based brokerage fees. We have controls established to identify and mitigate this risk. RRs also have an incentive to provide higher levels of service to those clients who generate the most fees.

Recruitment compensation is provided to RRs who join our firm from another financial firm. This compensation, which may vary by RR, often includes either an upfront or backend award based upon new client assets to the firm and/or revenue generated from such client assets. This creates an incentive for the RR to recommend the transfer of assets to the firm, including brokerage assets, in order to earn this compensation.

Other RR Activities

RRs may be motivated to place trades ahead of clients in order to receive more favorable prices than their clients.

RRs who are transitioning through a succession plan may be incentivized to make brokerage recommendations designed to increase the value of their “book of business” through asset accumulation or brokerage trades that are not in your best interest. RRs who receive clients from a retiring RR are incentivized to meet growth goals and may make recommendations not in your best interest.

Internal campaigns and recognition efforts incentivize RRs to engage in activities to reach incentive goals.

Certain securities registrations govern the types of investments our RRs may engage in. For example, a RR with a “Series 6” registration is limited to mutual fund sales, while a RR with a “Series 7” registration is able to offer equities, bonds, mutual funds, options, etc. RRs of our broker-dealer are compensated by commission. Investment Advisor Representatives (IARs) with a “Series 65 or 66” may engage in offering Investment Advisory Services which are offered through our affiliate Registered Investment Advisor (RIA), Linden Thomas Advisory Services, LLC. IARs of our RIA are compensated by fee. For further detail on the registrations of your RR or IAR, you may review their profile on the FINRA website at brokercheck.finra.org.

Additional Resources

RRs may be motivated to place trades ahead of clients in order to receive more favorable prices than their clients.

RRs who are transitioning through a succession plan may be incentivized to make brokerage recommendations designed to increase the value of their “book of business” through asset accumulation or brokerage trades that are not in your best interest. RRs who receive clients from a retiring RR are incentivized to meet growth goals and may make recommendations not in your best interest.

Internal campaigns and recognition efforts incentivize RRs to engage in activities to reach incentive goals.

Certain securities registrations govern the types of investments our RRs may engage in. For example, a RR with a “Series 6” registration is limited to mutual fund sales, while a RR with a “Series 7” registration is able to offer equities, bonds, mutual funds, options, etc. RRs of our broker-dealer are compensated by commission. Investment Advisor Representatives (IARs) with a “Series 65 or 66” may engage in offering Investment Advisory Services which are offered through our affiliate Registered Investment Advisor (RIA), Linden Thomas Advisory Services, LLC. IARs of our RIA are compensated by fee. For further detail on the registrations of your RR or IAR, you may review their profile on the FINRA website at brokercheck.finra.org.

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get started building wealth in less than five minutes!

Making the decision to use Indexperts as your digital wealth management platform is just smart. Investing with an award winning firm that uses Institutional Indexing as the platform for growth, no matter what the market conditions. Enter your info and let's get started.


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