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:"
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.
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:
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:
ADVISORS INNER CIRCLE
ADVISORS SERIES TRUST
ALPS SERVICE CO
AXS FF FUND GROUP
BABSON FUND FAMILY
BMO FUNDS MARH
CAPITOL SERIES TRUST
COHEN & STEERS
DAVIS SUBACCOUNTING FUND FAMILY
FIRST FOCUS FUNDS FFCF
HOTCHKIS AND WILEY
INVESTMENT MGRS SERIES TRUST
LIBERTY STREET FUNDS
MANAGED PORTFOLIO SERIES
MANNING AND NAPIER
MUTUAL FUND SERIES TRUST
NORTHERN LIGHTS FUNDS
PHAEACIAN FF FG
RBC FUNDS TRUST
SCHRODER FUND FAMILY
SELECTED SUBACCOUNTING FAMILY
T ROWE PRICE
TRUST FOR ADVISED PORTFOLIOS
ULTIMUS MANAGERS TRUST FF
Revenue Sharing Arrangements (Annuities)
Janney has entered revenue sharing agreements with the following insurance companies with respect to certain annuity policies offered to clients:
Jackson National Life
New York Life
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