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ERISA Section 408(b)(2) Notice Disclosures

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Important Qualified Retirement Plan Information for Plan Fiduciaries
Janney appreciates how important it is to keep qualified retirement plan sponsors informed and up to date on the services we provide and the resulting compensation we receive. This page contains information that relates to and supplements the required ERISA Section 408(b)(2) notices we provide to ERISA plan sponsors and other plan fiduciaries consistent with our disclosures obligations under the U.S. Department of Labor’s 408(b)(2) regulations. In particular, the information included here relates to:

• Revenue Sharing Arrangements with Respect to Mutual Fund Investments
• Networking Reimbursements (Networking and Omnibus Arrangements) with Respect to Mutual Fund Investments
• Revenue Sharing Arrangements with Respect to Annuity Policies
• Schedule of Account Charges

If you are not the fiduciary for your qualified plan, please forward the disclosure notices you received, as well as the link to this webpage, to the plan fiduciary or ask the plan fiduciary to contact your Janney Financial Advisor to obtain our required disclosures.

Revenue Sharing Arrangements (Mutual Funds) 
Janney has entered revenue sharing agreements with the following mutual fund underwriters, distributors or advisors, known as our “Product Partners:"

Allianz
American Century
American Funds
Eaton Vance
Federated
Franklin Templeton
Hartford
Henderson
ING/Voya
Ivy
John Hancock
JP Morgan
Legg Mason
Lord Abbett
MFS
Neuberger Berman
NY Life / MainStay
Oppenheimer
PIMCO
Principal
Prudential
Putnam
Touchstone
Russell

The revenue share payments vary by fund family and are generally based on an annual percentage of the average daily assets invested in a fund ranging from 0.02% (2 basis points (2bps)) to 0.10% (10 bps), as well as an annual percentage of new or gross sales of fund shares generally ranging from 0.05% (5 bps) to 0.10% (10 bps). Additionally, some fund families may make fixed payments in addition to the above payments or instead of those payments. A number of fund families exclude assets in particular share classes (such as institutional and retirement share classes) and/or funds (such as index or money market funds) when calculating the revenue share payments.

The revenue share payments to Janney are from the fund’s investment advisor, principal underwriter or distributor and are in addition to the sales charges, 12b-1 fees and deferred sales charges in the funds’ prospectus fee table. During calendar year 2015, Janney received a total of $2,619,318 in revenue sharing payments from mutual fund underwriters, distributors and advisors. Our Financial Advisors do not share in or otherwise receive any portion of these payments or receive any direct economic benefit from these payments, and they are not required to recommend these funds.


For more information about revenue sharing compensation, please refer to the mutual fund prospectus previously provided.

Networking Reimbursements
Networked Basis
Trading on a Networked Basis means Janney submits a separate trade for each individual client trade to the fund and therefore we maintain only certain elements of the fund’s shareholder information. To defray the cost of sending confirmations, statements and tax reporting, Janney receives networking reimbursements from certain mutual funds. These charges typically are based upon the number or aggregate value of client positions and the levels of service provided. On a networked basis, the fees range from $3.00 - $10.00 per client account per year, paid quarterly. Our Financial Advisors do not share in or otherwise receive any portion of the reimbursements or receive any direct economic benefit from these payments, and they are not required to recommend these funds.

For the year ending December 31, 2015, Janney received networking reimbursement from the following mutual fund companies:


Aberdeen
Alger
Alliance
ALLIANZ Funds
American Century
American Funds
Aquila Funds
Blackrock Funds
Calamos Funds
Calvert Funds
Columbia/RiverSource/Seligman
Davis Funds/Selected Funds
Delaware Funds
Dreyfus Funds
DWS Scudder/Kemper
Eagle Funds
Eaton Vance Funds
Federated Funds
Fidelity Funds
Franklin Templeton Funds
Goldman Sachs
Harbor Funds
Hartford Funds
Henderson Funds
Highmark Funds
Hotchkis & Wiley Funds
ING Funds
Invesco Funds
Ivy / Waddell & Reed Funds
JP Morgan / One Group
John Hancock Funds
Kinetics
Legg Mason Funds
Loomis Sayles
Lord Abbett Family of Funds
Mainstay Funds
MFS
Munder Funds
NATIXIS Funds
Neuberger Funds
Nuveen Funds
Oppenheimer Funds
PIMCO Funds
Pioneer Funds
Prudential Funds
Putnam Funds
Royce Funds
Russell Funds
Sentinel Funds
SunAmerica
T. Rowe Price
Thornburg Funds
Touchstone Funds
Transamerica Funds
Victory Funds
Virtus Funds
Wells Fargo Funds

Omnibus Basis
Janney is in the process of converting its top thirty fund families from a networked basis to an omnibus basis. This means we consolidate our clients' trades into larger, less frequent daily trade with the fund, enabling Janney to maintain all pertinent individual shareholder information for the fund. Trading in this manner requires that we 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. We charge those funds with administrative service fees on average $17 per year per client position. Because omnibus trading offers economies, for Janney and the funds, that are greatest when daily trade volumes are high, we have sought to establish omnibus trading arrangements with the fund families that clients trade the most. This may create a conflict of interest in the form of an additional financial incentive and financial benefit to the firm, its financial advisors and equity owners in connection with the sale of fund families trading on an Omnibus Basis.

As of December 31, 2015, we were trading on an omnibus basis with:

ABN AMRO
ABSOLUTE ADVISERS
ADVISORS INNER CIRC
AEGIS
AIP ALTERNATIVE
AKRE CAPITAL MANAGEMENT
AL FRANK
ALGER
ALLIANCEBERNSTEIN
ALPINE
AMANA FUNDS
AMERICAN BEACON
AMERICAN CENTURY
AMERICAN GROWTH
AMF
AMIDEX
API FUNDS
APPLESEED FUND
AQR
AQUILA FUNDS
ARBITRAGE
ARIEL
ARROW FUNDS
BAIRD FUNDS
BARON
BBH
BERKSHIRE
BERWYN
BRANDYWINE
BRIDGEWAY
BROWN CAPITAL
BROWN/IA
BUFFALO
BULL MOOSE
BURNHAM
CALVERT
CAMBIAR AIC
CATALYST FUNDS
CAUSEWAY
CENTURY FUNDS
CHASE GROWTH
COHEN & STEERS
COLUMBIA
CONESTOGA FAMILY OF FUNDS
COPELAND
CREDIT SUISSE
CRM
CULLEN
CUSHING MLP FUNDS
DESTRA CAPITAL
DIAMOND
DIREXION
DODGE & COX
DOMINI
DOUBLELINE FUNDS TRUST
DREMAN
DRIEHAUS
DUNHAM FUNDS
EAGLE
FAIRHOLME
FENIMORE
FIDELITY
FINANCIAL INVESTORS
FIRST AMERICAN
FIRST EAGLE
FIRST TRUST
FIRSTHAND
FORESTER
FORUM FUNDS
FORWARD
FPA
FUNDVANTAGE
GLENMEDE
GOLDMAN SACHS
GREEN CENTURY
GREENSPRING
GUINNESS ATKINSON
HARDING
HAVERFORD
HENNESSY
HIGHLAND
HIGHMARK
HODGES
HOMESTEAD
HOTCHKIS & WILEY
HUSSMAN
ICON
INGENUITY FUNDS
INTEGRITY
INVESCO FUNDS
INVESTMENT MANAGERS SERIES TR
ISI
IVA FIDUCIARY TRUST
JACOB
JENSEN
KEELEY
LAUDUS FUNDS
LAZARD
LEUTHOLD
LIBERTY STREET HORIZON
LONGLEAF FUNDS
MADISON MOSAIC
MAIRS
MANAGED PORTFOLIO SERIES
MANAGERS FUND
MANNING & NAPIER
MARSICO
MASTERS
MATTHEWS
MERGER
MERK FUNDS
METROPOLITAN
MFS
MMA PRAXIS MUTUAL
MORGAN STANLEY
MUNDER
NATIONWIDE
NICHOLAS
NORTHEAST
NORTHERN LIGHTS FUNDS
NUVEEN
OAK
OAKMARK
OBERWEIS
OLSTEIN
OSTERWEIS
PACIFIC
PARNASSUS
PAX WORLD
PEAR TREE FUNDS
PERMANENT PORTFOLIO
PNC FUNDS
PORTFOLIO 21
PRIMECAP
PRINCIPAL
PROFESSIONALLY MANAGED
PROFUNDS
PRUDENTIAL
PUTNAM
RBC CENTURA
REYNOLDS
RIDGEWORTH CAPITAL MANAGEMENT
RIVERPARK FUNDS
ROBECO BOSTON PRTNRS
RS FUNDS
RYDEX
SARATOGA
SATUIT
SCHWAB
SCHWARTZ
SEI
SIT
SNOW CAPITAL
SOUND SHORE
SOUTHERNSUN FUNDS
SSGA
STADION
STEELPATH MLP FUNDS TR
STERLING CAPITAL FUNDS
STRATTON
SUNAMERICA
TAMARACK FUNDS
TANAKA
TCW
TFS
THIRD AVENUE
THOMPSON PLUMB
THORNBURG
TIAA-CREF
TILSON FUNDS
TIMOTHY PLAN
TOCQUEVILLE
TRANSAMERICA
TRANSPARENT VALUE TR
TRUST FOR PROFESSIONAL MANAGERS
TURNER
TWEEDY
UBS
UMB
US GLOBAL INVESTORS
VALUE ADVISERS
VALUE LINE
VAN ECK
VILLERE FUNDS
VIRTUS FUNDS
WHG
WILLIAM BLAIR
WORLD FUNDS

Revenue Sharing Arrangements (Annuities)
Janney has entered revenue sharing agreements with the following insurance companies with respect to certain annuity policies offered to clients:

Allianz
AIG Financial
AXA
Fore Thought Life
Hartford Life
Jackson National Life
Lincoln Financial
Met Life
Nationwide
Ohio National
Pacific Life
Prudential
Transamerica

The revenue share payments vary by insurance company and are generally based on an annual percentage of new or gross sales ranging from 0.15% (15 bps) to 0.20% (20 bps).

The revenue share payments to Janney are from the insurance company or its affiliate and are in addition to commissions received. During calendar year 2015, Janney received a total of $467,236 in revenue sharing payments from insurance companies. No revenue sharing payments are received with respect to group annuities held by retirement plans maintained on the annuity provider’s record keeping platform.


Schedule of Account Service Charges 
Click here for an overview of customary account and client service fees. Your Financial Advisor can also provide you with a copy.