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:" 

 Allianz 

 American Century 

 American Funds 

 Eaton Vance 

 Federated 

 Franklin Funds 

 Hancock

 Hartford 

 ING/VOYA

 JP Morgan 

 Legg Mason 

 Lord Abbett

 Mainstay Investments

 MFS

 Neuberger Berman 

 Oppenheimer 

 Invesco

 PIMCO 

 Principal Life

 Prudential Investments

 Putnam 

 Russell

 Touchstone 

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 2019, Janney received a total of $2,304,317.97 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. 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 FUNDS

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

 Great West

 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 2019, Janney received a total of $541,992.11 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

Related Documents & Forms

For more information about Janney, please see Janney’s Relationship Summary (Form CRS) on www.janney.com/crs which details all material facts about the scope and terms of our relationship with you and any potential conflicts of interest.

To learn about the professional background, business practices, and conduct of FINRA member firms or their financial professionals, visit FINRA’s BrokerCheck website: http://brokercheck.finra.org/