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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
Ivy
John Hancock
JP Morgan
Legg Mason
Lord Abbett
MFS
Neuberger Berman
NY Life / MainStay
Oppenheimer
PIMCO
Principal
Prudential
Putnam
Russell
Touchstone 
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 2017, Janney received a total of $2,223,198.39 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, 2016, 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. 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, 2017, we were trading on an omnibus basis with:

ABERDEEN FUNDS
ACAP STRATEGIC FUND
ACR FUNDS
ACR FUNDS
AEGIS FUNDS
ALGER FUNDS
ALGER SICAV OFFSHORE FUNDS
ALLEGIANT FUNDS
ALLIANCE GLOBAL INVESTOR SVCS
ALLIANZ FUNDS
ALPINE REAL ESTATE FUNDS
ALPS FUNDS
ALTEGRIS FUNDS
AMANA FUNDS
AMERICAN BEACON FUNDS
AMERICAN CENTURY FUNDS
AMERICAN FUNDS SERVICE CO
AMERICAN GROWTH FD
AMERICAN TRUST ALLEGIANCE FUND
AMG FUNDS
AMIDEX FUNDS INC
ANGEL OAK FUNDS
APEX FUNDS
API FUND
AQR FUNDS
AQUILA GROUP OF FUNDS
ARBITRAGE FUNDS
ARIEL MUTUAL FUNDS
ARTIO GLOBAL FUNDS
ARTISAN PARTNERS FUNDS
ASHMORE FUNDS
ASSET MANAGEMENT FUNDS
AVE MARIA FUNDS
BABSON CAPITAL FUNDS TRUST
BAIRD FUNDS, INC
BARON FUNDS
BBH FUNDS
BERKSHIRE FUNDS
BERWYN FUNDS
BLACKROCK FUNDS
BLACKSTONE FUNDS
BNY HAMILTON FUNDS
BOYAR VALUE FUND
BP CAPITAL FUNDS
BRANDES FUNDS
BRIDGEWAY FUNDS, INC
BRIGHT DIRECTIONS 529 PLANS
BROADVIEW FUNDS
BROOKFIELD INVESTMENT FUNDS
BROWN ADVISORY FUNDS
BROWN CAPITAL MANAGEMENT
BUFFALO FUNDS
CALAMOS FUNDS
CALVERT GROUP
CARILLON FAMILY OF FUNDS
CATALYST FUNDS
CAUSEWAY FUNDS
CENTRE FUNDS
CLAYMORE FUNDS
COHEN & STEERS FUNDS
COLLEGEBOUND 529 PLANS
COLLEGECHOICE 529 SAVING PLAN
COLLEGECOUNTS 529 FUND
COLUMBIA FUNDS SERVICES, INC
CONESTOGA FUNDS
CONGRESS FUNDS
CREDIT SUISSE INSTL FUND, INC
CREDIT SUISSE WARBURG PINCUS
CRM FUNDS
CULLEN FUNDS TRUST
DAVIDSON FUNDS
DAVIS FUNDS
DELAWARE INVESTMENTS
DESTRA FUNDS
DFA FUNDS
DIAMOND HILL FUNDS
DIREXION FUNDS
DIVIDEND GROWTH TRUST FUNDS
DODGE & COX FUNDS
DOMINI FUNDS
DOUBLELINE FUNDS
DREYFUS SERVICE CORP
DRIEHAUS FUNDS
DUNHAM FUNDS
DWS INVESTMENTS SERVICE CO
EATON VANCE GROUP
EQUINOX FUNDS
EVENTIDE FUNDS
EVERMORE FUNDS
FAIRHOLME FUNDS
FAM FUNDS
FAMCO FUNDS
FEDERATED FUNDS
FIDELITY ADVISOR FUNDS
FINANCIAL INVESTORS TRUST
FIRST EAGLE FUNDS
FIRST INVESTORS CORP
FIRST TRUST FUNDS
FIRSTHAND FUNDS
FMI FUNDS
FORESTER FUNDS, INC
FORUM FUNDS
FORWARD/EMERALD FUNDS
FPA FUNDS
FRANKLIN TEMPLETON
FROST FUNDS
FUNDVANTAGE FUNDS
GABELLI FUNDS
GATEWAY FUNDS
GLENEMEDE FUNDS
GOLDMAN SACHS FUNDS
GREEN CENTURY FUNDS
GREENSPRING FUND INC
GUGGENHEIM INVESTMENTS
GUINNESS ATKINSON FUNDS
HANCOCK HORIZON FUNDS
HARBOR FUNDS
HARDING LOEVNER FUNDS
HARTFORD FUNDS
HATTERAS FUNDS
HEARTLAND FUNDS
HENNESSY FUNDS, INC
HIGHLAND FUNDS
HODGES FUND
HOMESTEAD FUNDS
HOTCHKIS AND WILEY FUNDS
HUSSMAN FUNDS
ICON FUNDS
INDEX IQ FUNDS
INTEGRITY MUTUAL FUNDS INC
INVESCO FUNDS
IVA FUNDS
IVY FUNDS
JACOB FUNDS
JAMES FUNDS
JANUS FUNDS
JENSEN FUNDS
JOHCM FUNDS
JOHN HANCOCK FUNDS
JP MORGAN FUNDS
KEELEY FUNDS
KINETICS MUTUAL FUNDS INC
KOPERNIK FUNDS
LAUDUS ROSENBERG FUNDS
LAZARD FUNDS
LEADER FUNDS
LEGG MASON FUNDS
LEUTHOLD FUNDS
LIBERTY STREET HORIZON FUNDS
LOCORR FUNDS
LONESTAR 529 PLANS
LONGLEAF PARTNERS FUNDS
LOOMIS SAYLES FUNDS
LORD ABBETT FUNDS
LYRICAL FUNDS
MADISON FUNDS
MAINGATE FUNDS
MAINSTAY FUNDS
MAIRS & POWER FUNDS
MANNING & NAPIER FUNDS
MARKETFIELD FUNDS
MARSICO FUNDS
MASTERS SELECT FUNDS
MATTHEWS INTERNATIONAL FUNDS
METROPOLITAN WEST FUNDS
MFS MERIDIAN FUNDS
MFS SERVICE CENTER
MILLER FUNDS
MIRAE ASSET GLOBAL INVESTMENTS
MMA PRAXIS MUTUAL FUNDS
MORGAN STANLEY FUNDS
MUHLENKAMP FUND
NATIONS FUNDS
NATIONWIDE FUNDS
NATIXIS FUNDS
NEST 529 PLANS
NEUBERGER BERMAN FUNDS
NEW ALTERNATIVE FUND INC
NICHOLAS FUNDS
NORTHERN FUNDS
NORTHERN LIGHTS FUND TRUST
NUVEEN INVESTOR SERVICES
OAK ASSOCIATES FUNDS
OAK RIDGE FUNDS
OAKMARK FUNDS
OBERWEIS FUNDS
OLSTEIN FUNDS
OPPENHEIMER FUNDS SERVICES
PACIFIC FUNDS
PACIFIC INCOME ADVISERS
PARNASSUS FINANCIAL MANAGEMENT
PAX WORLD FUNDS
PEAR TREE FUNDS
PERMANENT PORTFOLIO FUNDS
PIMCO FUNDS
PIMCO INSTITUTIONAL FUNDS
PIONEER INVESTMENTS
PNC FUNDS INC
PRIMECAP ODYSSEY FUNDS
PRINCIPAL MUTUAL FUNDS
PROFESSIONALLY MANAGED FUNDS
PROFUNDS
PRUDENTIAL MUTUAL FUND
PUTNAM INVESTMENTS
QUAKER FUNDS
RBB FUNDS INC
RBC FUNDS
REINHART FUNDS
REYNOLDS FUNDS
RIVERBRIDGE FUNDS
RIVERPARK FUNDS
RMB FUNDS
ROYCE FUNDS
RS FUNDS
RUSSELL FUNDS
SARATOGA CAPITAL MANAGEMENT
SCHWAB FUNDS
SEI FUNDS
SIT MUTUAL FUNDS
SNOW CAPITAL FUNDS
SOUND SHORE FUNDS
SSGA FUNDS
STADION FUNDS
STERLING CAPITAL FUNDS
STRATTON FUNDS
SUN AMERICA FUNDS
T ROWE PRICE
TANAKA FUNDS
TCW GALILEO FUNDS
THE AL FRANK FUND
THE MERGER FUND
THE MUNDER FUNDS
THIRD AVENUE VALUE FUND
THOMAS WHITE FUNDS
THOMPSON PLUMB FUNDS
THORNBURG SEC CORP
TIAA-CREF MUTUAL FUNDS
TIMOTHY PLAN FUNDS
TOCQUEVILLE FUNDS
TORTOIS MLP PIPELINE FUNDS
TOUCHSTONE FUNDS
TRANSAMERICA FUNDS
TRANSAMERICA PREMIER FUNDS
TRANSPARENT VALUE FUNDS
TWEEDY BROWNE FUNDS
U S GLOBAL INVESTORS FUNDS
UBS FUNDS
ULTIMUS FUND SOLUTIONS
USAA FUNDS
VALUE LINE SECURITIES INC
VAN ECK SECURITIES CORP
VAN KAMPEN FUNDS
VANGUARD FUNDS
VICTORY FUNDS
VIRTUS FUNDS
VOYA FUNDS
WASATCH MUTUAL FUNDS
WEITZ FUNDS
WELLS FARGO FUNDS
WESTCORE FUNDS
WILLIAM BLAIR FUNDS
WILMINGTON FUNDS
WILSHIRE FUNDS
WINTERGREEN FUNDS
WORLD FUNDS TRUST

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 2017, Janney received a total of $368,000 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.