ERISA Section 408(b)(2) Notice Disclosures
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:"
American Century
American Funds
Eaton Vance
Federated
Franklin Templeton
Hartford
Invesco
JP Morgan
Legg Mason
Lord Abbett
Mainstay Investments
Neuberger Berman
PIMCO
Principal
PGIM
Putnam
Russell
Touchstone
Virtus
Voya
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 2020, Janney received a total of $2,278,182.66 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, 2020, Janney received networking reimbursement from the following mutual fund companies:
Aberdeen
Alger
Alliance
American Century
American Funds
Columbia/RiverSource/Seligman
DWS Scudder/Kemper
Fidelity Funds
ING Funds
Invesco Funds
Nuveen Funds
Oppenheimer Funds
Prudential Funds
Putnam Funds
State Street
USAA Funds
Omnibus Basis
Janney processes its mutual fund transactions through an omnibus relationship with Charles Schwab. 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. Janney does not receive sub-transfer agency payments ("Sub-TA fees") on ERISA advisory accounts. 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, 2020, we were trading on an omnibus basis with:
1919 FUND
ABERDEEN
ADVISORS INNER CIRCLE
ADVISORS SERIES TRUST
AEGIS
ALGER
ALLIANCE BERNSTEIN
ALLIANZ
ALPS SERVICE CO
AMANA
AMERICAN BEACON
AMERICAN CENTURY
AMERICAN FUNDS
AMERICAN GROWTH
API
AQR
AQUILA
ARBITRAGE
ARROW
ARTISAN
ASHMORE
AXS FF FUND GROUP
BABSON FUND FAMILY
BARON
BBH
BLACKROCK
BLACKSTONE BLST
BMO FUNDS MARH
BRANDES
BRIDGEWAY
BROOKFIELD
BROWN ADVISORY
BUFFALO
BURNHAM
CALAMOS
CALVERT
CAMBIAR
CAMPBELL
CAPITAL INVESTMENT
CAPITOL SERIES TRUST
CAPSTONE
CATALYST
CAUSEWAY
CENTRE
COHEN & STEERS
COLUMBIA
CONESTOGA
COPELAND
CRA FUNDS
CREDIT SUISSE
CRM
CULLEN
DAVIS SUBACCOUNTING FUND FAMILY
DEAN DEAN
DELAWARE
DFA DFA
DIAMOND HILL
DOMINI
DOUBLELINE
DREMAN
DREYFUS
DRIEHAUS
DUNHAM
DWS INVESTMENTS
EAGLE
EATON VANCE
EVERMORE
FEDERATED
FIDELITY
FIRST EAGLE
FIRST FOCUS FUNDS FFCF
FIRST TRUST
FORUM
FORWARD
FRANKLIN TEMPLETON
FROST
FUNDVANTAGE
GABELLI
GERSTEIN
GLENMEDE
GOLDMAN SACHS
GUGGENHEIM
GUINNESS ATKINSON
HANCOCK HORIZON
HARBOR
HARTFORD
HEARTLAND HEAR
HENNESSY
HIGHLAND
HIGHMARK
HODGES
HOMESTEAD
HOTCHKIS AND WILEY
IDEX
INTEGRITY
INVESCO
INVESTMENT MGRS SERIES TRUST
IVA
IVY
JAMES FUNDS
JANUS
JENSEN
JOHN HANCOCK
JP MORGAN
KEELEY
KINETICS
LAZARD
LEGG MASON
LEUTHOLD
LIBERTY STREET FUNDS
LITMAN
LOCORR
LOOMIS SAYLES
LORD ABBETT
MADISON
MAINGATE
MAINSTAY
MANAGED PORTFOLIO SERIES
MANAGERS
MANNING AND NAPIER
MATTHEWS ASIA
MERIDIAN
METROPOLITAN WEST
MFS
MILLER
MORGAN STANLEY
MUTUAL FUND SERIES TRUST
NATIONWIDE
NATIXIS
NEUBERGER BERMAN
NORTHERN
NORTHERN LIGHTS FUNDS
NUVEEN
OAK RIDGE
OAKMARK
OBERWEIS
OLSTEIN
OPPENHEIMER
PACIFIC LIFE
PARNASSUS
PAX WORLD
PEAR TREE
PHAEACIAN FF FG
PIMCO FUNDS
PIONEER
PNC
PORTFOLIO
PRAXIS
PRINCIPAL
PROFUNDS
PRUDENTIAL
PUTNAM
QUAKER
RBB TRUST
RBC FUNDS TRUST
RIVERBRIDGE
RIVERPARK
ROYCE
RS INVESTMENTS
RUSSELL
SARATOGA
SCHRODER FUND FAMILY
SCHWAB
SCOUT
SEI
SELECTED SUBACCOUNTING FAMILY
SHELTON
SNOW CAPITAL
SOUTHERNSUN
SRPT FF
SSGA
STADION
STERLING
SUNAMERICA
T ROWE PRICE
TCW
THORNBURG
TIAA CREF
TIMOTHY PLAN
TOCQUEVILLE
TOUCHSTONE
TRANSPARENT VALUE
TRUST FOR ADVISED PORTFOLIOS
UBS
ULTIMUS MANAGERS TRUST FF
USAA
VALUE ADVISORS
VALUE LINE
VAN ECK
VICTORY
VIRTUS
VOYA
WASATCH
WELLS FARGO
WESTCORE
WHG
WILLIAM BLAIR
WILMINGTON
Revenue Sharing Arrangements (Annuities)
Janney has entered revenue sharing agreements with the following insurance companies with respect to certain annuity policies offered to clients:
AIG Financial
Allianz
AXA
Forethought Life
Jackson National Life
Lincoln Financial
Met Life/BrightHouse
New York Life
Nationwide
Pacific Life
Prudential
Symetra/Riversource
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 2020, Janney received a total of $514,685.97 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