About Us Raymond James & Associates, Inc. (“RJA”) is a wholly owned subsidiary of Raymond James Financial, Inc. (“RJF”), a publicly held corporation based in Saint Petersburg, Florida. RJA is registered with the Securities and Exchange Commission (“SEC”) as a broker-dealer since 1962 and as an investment adviser since 1974. Registration as an investment adviser with the SEC does not imply a certain level of skill or training. As a sponsor of the wrap fee programs described in this Brochure, RJA organizes or administers the programs including, with regard to certain programs, selecting investments or providing advice regarding the selection of other investment advisers in the program. The wrap fee programs that RJA sponsors may be offered by financial advisors affiliated with RJA or financial advisors of our affiliated investment adviser, Raymond James Financial Services Advisors, Inc. (“RJFSA”). RJA’s sponsored wrap-fee programs are also available through financial advisors of other non-affiliated independent investment adviser firms. The Asset Management Services (“AMS”) division of RJA provides a variety of support services to the various wrap-fee programs including, but not limited to fee-billing, model portfolio implementation, portfolio management, due diligence, and financial advisor support. We use the term financial advisor or investment adviser representative (“IAR”) to mean the individual representative that you work with when choosing a program. The following chart details the affiliation through which an IAR could offer our wrap- fee program accounts: IAR’s Firm Association Type of Relationship with RJA RJA Your financial advisor is an employee of RJA, and generally is both an investment adviser representative and a registered representative of RJA, a dually registered investment adviser and broker-dealer. Raymond James Financial Services Advisors, Inc. (“RJFSA”) Your IAR is an investment adviser representative of RJFSA but is associated through an independent contractor office or branch. Your IAR may also be a registered representative of our affiliated registered broker-dealer, Raymond James Financial Services, Inc. (“RJFS”). Independent Investment Adviser/Raymond James Financial Services, Inc. (“RJFS”) 1 Your IAR may offer investment advisory services through a non- affiliated independent registered investment adviser (as part of an outside business activity) and also be a registered representative of RJFS for brokerage services. RIA & Custody Services Division (“RCS”) 1 Your IAR is associated with a non-affiliated independent registered investment adviser that has a sub-advisory agreement with RJA to offer our various managed account programs to their clients. Your IAR may also be registered with a broker-dealer that is not affiliated with RJA, RJFS, or RJFSA. 1 In the case of our “IAR Managed” (as defined below) investment advisory program, when offered through independent registered investment adviser firms, the independent investment adviser firm and not Raymond James is your investment adviser providing investment advice to you, not RJA or its affiliates. In some programs (“AMS Managed Programs”, as defined below), RJA, through AMS, will act as subadviser while the firm with which your IAR associates is your primary investment adviser and responsible for assessing your investment objectives based on the information you initially provide, to determine which advisory programs, if any, are appropriate to recommend to you. We tailor our advisory services to your individual needs. We encourage you to share your current financial situation, needs, and objectives, as well as changes in your financial and personal circumstances, with your financial advisor so that appropriate advice may be provided to you. In the case of our “IAR Managed” (as defined below) advisory program, the IAR provides discretionary or non-discretionary investment advice to you and RJA provides administrative and wrap billing services as sponsor to the program. The firm with which your IAR associates, which may not be RJA or an affiliate of RJA, is responsible for investment advice. When offered through independent investment adviser firms, the independent investment adviser firm and not Raymond James is your investment adviser. Financial advisors and branch offices may use marketing or other branch names that are held out to the public. These branch or marketing names are accompanied by the phrase “of Raymond James”. The purpose of using a branding or marketing name is for the financial advisor to create a brand that is specific to the individual financial advisor and/or branch. Financial advisors offering advisory services are required to provide you with a current Form ADV Part 2B (“Brochure Supplement”), which includes information regarding the financial advisor’s education, business experience, disciplinary information, other business activities, additional compensation, and supervision. You may also obtain additional information regarding your financial advisor, such as licenses, employment history, their regulatory disciplinary information (if any), and whether he or she has received reportable complaints from investors from the SEC at adviserinfo.sec.gov. Should you have any concerns regarding any of the information contained in your Raymond James financial advisor’s Brochure Supplement, you are encouraged to contact our Advisory Compliance Department at 800-248-8863, extension 75877. As used in this Brochure, the words “we,” “our,” “our Firm,” “the Firm,” “RJA,” and “us” refer to RJA and your financial advisor, and the words “you,” “your,” and “client” refer to you as either a client or prospective client of our Firm. Assets Under Management As of September 30, 2023, we had approximately $350.041 billion in assets under management, approximately $250.394 billion of which was managed on a discretionary basis and approximately $99.647 billion of which was advised on a non-discretionary basis. Types of Services RJA offers advisory programs and other advisory services which are not described in this Brochure. Depending on the services your financial advisor provides and/or the type of services or program(s) you select, you will be provided a copy of the appropriate brochure related to such advisory program. As described below, these brochures provide detailed information, disclosures, and potential conflicts of interest related to other advisory services, outside of our wrap fee programs, that we may provide you.
• RJA Form ADV Part 2A – We offer financial planning and/or investment consulting services to our clients through our Wealth Advisory Services Program. Detailed information about these and other services offered through RJA are available in the RJA Form ADV Part 2A Brochure. A copy is available, upon request, from your financial advisor or you may visit our public website: https://www.raymondjames.com/legal-disclosures.
• Institutional Fiduciary Solutions (“IFS”) Form ADV Part 2A – Your financial advisor offers advisory consulting services to institutional and qualified retirement plans, including program support, investment education and guidance, if selected by a client. IFS, a division of RJA, supports and maintains oversight over these activities. Details of the services provided by IFS are available in the IFS Form ADV Part 2A Brochure. A copy is available, upon request, from your financial advisor or you may visit our public website: https://www.raymondjames.com/legal-disclosures. Note for Non-U.S. Persons: RJA and RJFSA are U.S.-based, SEC-registered investment advisers. We do not provide products and services in or into all countries. The products and services that we can offer or provide to you, and how we interact with you, may be limited based upon where you reside or are physically located, or other jurisdictional connections related to your account (for example, country of formation and countries in which authorized persons or beneficial owners reside, in the case of an account for a legal entity). We may limit products and services, decline to open an account, and/or close an existing account based upon such jurisdictional connections. Wrap Fee Sponsored Programs Offered Within our advisory programs, we offer separately managed account, multiple discipline account, unified managed account, mutual fund and/or exchange-traded fund (“ETF”) asset allocation programs through the Asset Management Services (“AMS”) division of RJA (each, an “AMS Managed Program”) and a dual contract managed account platform, also through AMS, in which you enter into both an advisory agreement with us for non-discretionary services and a separate contract with an outside manager for discretionary management. RJA also sponsors a program where your individual financial advisor or IAR, advises you in either a discretionary or non-discretionary capacity, on your account assets (“IAR Managed Program”). While RJA is the wrap fee program sponsor of the IAR Managed Program, the financial advisor and its associated registered investment adviser is providing you advisory services. Each of the AMS Managed Programs is a discretionary program with AMS exercising discretionary authority as described below, and your IAR generally acting in a non-discretionary capacity in recommending the program. Whereas in the IAR Managed Program the account can be established as a discretionary or non-discretionary account and, in either case, your IAR provides the respective services. In an IAR managed discretionary account, you delegate to your investment adviser the authority to decide what securities to buy or sell for your account. In an IAR managed non-discretionary account, your investment adviser will provide you with advice in the form of recommendations but the decision to buy or sell securities is made by you. Your delegation of investment discretion to RJA will generally result in securities and other investment prospectuses (and other associated regulatory mailings) being accessible to RJA as the program’s Manager for investment purposes and these documents will not be delivered to you as is otherwise customary or required when you make the investment decisions. However, we will make these documents available to you upon request. The RJA-sponsored wrap fee programs described in this Brochure are programs in which you pay a single bundled or “wrap” asset-based fee for both advisory and brokerage services. This fee generally includes compensation paid to RJA for execution, clearing, custodial, and other administrative services, and in the AMS Managed and IAR Managed Programs, advisory services, as well as compensation paid to your financial advisor and any investment adviser associated with providing investment advisory services under the program, which can include RJA and its affiliated investment advisers, as well as third-party managers. Advisory services within a wrap fee program may include portfolio management or advice concerning the selection of other investment advisers. Generally, securities transactions in our wrap fee programs are effected “net” (i.e., without commission) and a portion of the wrap fee is generally considered to be inclusive of commission charges. For details on the fees you will pay under our wrap fee programs, including additional expenses that can be incurred outside of the wrap fee, please refer to the “Additional Expenses” section and our fee schedules in the “Fee” section. AMS provides support services for clients and financial advisors through its AMS Managed Programs and IAR Managed Program, such as establishing custodial facilities, initiating and/or adjusting pre-existing periodic investment and disbursement/payment plans, cash disbursements, account inquiry services, billing and payment remittance support, sales and trading support, educational opportunities and training to financial advisors, and other account maintenance services. If you are a RJA advisory client, RJA acts as custodian or sub- custodian, as applicable, and broker for the execution of purchases and sales in your account. If you are a RJFSA advisory client, RJA acts as custodian or sub-custodian, as applicable, and RJFS acts as the introducing broker for the execution of purchases and sales in your account through RJA and RJFSA serves as your primary investment adviser and RJA is subadvisor with respect to the AMS Managed programs. For individual Retirement Custodial Accounts (IRAs), Raymond James Trust Company of New Hampshire is custodian and RJA is sub-custodian. The chart below provides an overview of the advisory programs we offer. Chart – Overview of our Advisory Programs Advisory Programs Investment Adviser(s)1, 2 Type of Program Discretionary Authority Maintained By Use of Affiliated Subadvisors and/or Mutual Funds Maximum Advisory Fee3 Investment Products/ Disciplines Investment Minimum4 Margin trading available Raymond James Consulting Services (“RJCS”) RJA & Separately Managed Account Managers (“SMA Managers”) SMA5 RJA or SMA Manager, dependent on selected strategy. Yes Equity & Balanced: 2.75%; Fixed Income: 2.55%; Laddered Bond and Short Term Conservative Fixed Income: 2.45% Fixed income Securities, Equities; Exchange Traded Funds and Alternative Investments $25K-$2M, dependent on selected strategy Certain disciplines may have higher minimum requirements, refer to Client Agreement for more information. No Multiple Discipline Account (“MDA”) RJA and SMA Managers (referred to as “MDA Managers”) MDA6 RJA or MDA Manager, dependent on selected strategy. Yes 2.60% Separately Managed Accounts and Exchange Traded Funds $300K-$500K, dependent on selected strategy No Raymond James Research Portfolios (“RJRP”) RJA Equity Program RJA7 No 2.60% Equities $100K No Freedom Unified Managed Account (“Freedom UMA”) RJA UMA8 RJA7 Yes 2.60% Separately Managed Accounts, Mutual Funds and Exchange Traded Funds $300K -$2M dependent on selected strategy; Certain disciplines may have higher minimum requirements, refer to Client Agreement for more information. No Portfolio Select Unified Managed Account (“Portfolio Select UMA”) RJA Custom UMA10, 13 IAR Discretionary or IAR Non- Discretionary 9 Yes 2.60% Separately Managed Accounts, Mutual Funds and Exchange Traded Funds, Equities $200K+ No Freedom RJA Mutual Fund/Exchange Traded Fund Asset Allocation11 RJA7 Yes 2.25% Mutual Funds and Exchange Traded Funds $5K-25K, dependent on selected strategy No American Funds Model Portfolios ("American Funds") RJA and Capital Research and Management Company Mutual Fund Asset Allocation RJA No 2.25% Mutual Funds $5K No Russell Investments Model Strategies ("Russell") RJA and Russell Investments Mutual Fund Asset Allocation RJA No 2.25% Mutual Funds $25K No BlackRock Model Portfolios RJA and BlackRock Undertakings for Collective RJA No 2.25% UCITS $100,000 No 1 Your financial advisor may be affiliated with RJA, RJFSA or an independent registered investment adviser; however, RJA organizes and administers the program, including, with regard to certain AMS Managed Programs, selecting investments or providing advice regarding the selection of other investment advisers in the program. 2 Via a sub-advisory agreement, except in Ambassador. 3Maximum Advisory Fee includes compensation to be paid to your financial advisor, RJA, and the investment manager (where applicable), unless otherwise noted. Please note that each program fee schedule has a reduced fee at progressively higher asset levels and only the maximum fee is listed above assuming the minimum required investment. Other fees may be applicable. Please refer to the “Additional Expenses” section for more details. For the OSM Platform, the fee shown reflects only RJA’s Platform fee. A separate OSM Manager fee also applies. Please refer to the “OSM Manager” description page for more details. 4 Below minimum accounts may be accepted based on individual circumstances of a client’s relationship with the firm and their advisor. Certain high net worth strategies within the AMS Managed Accounts Programs, may be available to eligible qualified purchasers, subject to higher account minimums. If you are a qualified purchaser, please consult with your financial advisor for more information. 5 Separately managed accounts (“SMAs”) are portfolios of individual securities managed by an investment management firm. AMS’s programs offer clients the opportunity to select professional investment management firms (also called money managers) to individually manage or provide model portfolio recommendations within their designated individually segregated accounts. You have the ability to segregate your assets from other investors, that is, you directly own all securities in the account. 6 A multiple discipline account (“MDA”) is a type of managed account where investment managers offer multiple investment disciplines in a single account. An MDA may also be known as a multi-strategy account and provide investors with a diversified, professionally managed portfolio. Within our MDA programs, clients can select a broad investment strategy developed by investment managers that employ multiple investment disciplines offered by that investment manager in a single account. 7 Investment discretion in this account program is exercised by RJA. The AMS Investment Committee oversees the program and determines the underlying investments. Please refer to the “Role of AMS Investment Committee in Developing the Strategies” section for a description of the AMS Investment Committee’s role in each program. 8 A unified managed account (“UMA”) is a type of advisory account where you combine multiple investments in a single account. UMA accounts provide the characteristics of traditional separately managed account models, mutual funds and exchanged trade funds in one “unified” account. You have the ability to select a strategy that combines SMA disciplines, mutual funds, and ETFs in a single account. 9 In the Portfolio Select UMA Program, while AMS maintains investment discretion in the account, your financial advisor either assists you in determining an appropriate asset allocation that is compatible with your needs and then assists you in constructing an investment portfolio by selecting investment products within each identified asset class or has selection discretion to select the investments and allocation within each investment option category. 10 A custom unified managed account (“CUMA”) is similar to a UMA account8. Our CUMA allows clients access to multiple investment strategies used separately in other existing advisory account programs available through RJA, RJFSA or an independent registered investment adviser. 11 Account allocations may consist of mutual funds and/or ETFs. 12 The BlackRock Program is offered solely to non-U.S. clients. 13 Accounts managed by your financial advisor either on a discretionary or non-discretionary basis. Overview of our Advisory Programs Raymond James Consulting Services (“RJCS”) Program (AMS Managed Program) The RJCS Program was developed to provide clients’ access to a number of investment management firms for account sizes below the investment managers’ (referred to generally, as “Managers”) typical minimums for servicing accounts directly. The RJCS Program operates within a separately managed account (“SMA”) structure in which the invested assets are owned directly by you in a single investment account. As sponsor of the RJCS Program, we enter into a subadvisory agreement with Model Managers and SMA Managers whose disciplines are offered in the Program (collectively, “RJCS Managers”). We select and perform ongoing due diligence on RJCS Managers and the offered disciplines in the RJCS Program. Additionally, as RJA has discretion to hire and fire RJCS Managers in the Program, RJA acts as a discretionary manager in its administration of the Program, although this discretionary authority does not extend to selecting and/or changing RJCS Managers or disciplines on your behalf. Invested assets in the disciplines are subject to discretionary management as well -- exercised by either RJA, if you select a Model Manager discipline, or the SMA Manager if you select an SMA Manager discipline. In a Model Manager arrangement, the Model Manager maintains the model portfolio and supplies their model recommendations to RJA. RJA exercises investment discretion in buying and selling assets subject to the selected Model Manager discipline and is responsible for organizing and effecting the portfolio trades. If you select a Model Manager’s investment discipline, investment advice is furnished solely by us to you. The Model Manager is not providing you with investment advice. The model portfolio and subsequent updates provided to RJA by the Model Manager is not based on the circumstances of or otherwise tailored to any individual client by the Model Manager. Most equity and certain balanced investment disciplines are offered in a model delivery arrangement. (“BlackRock”) Financial Management, Inc. Investment in Transferable Securities (“UCITS”)12 Outside Manager RJA and OSM Dual Contract SMA Platform OSM Manager No 2.25% RJA fee + OSM Manager Fee Refer to the OSM Manager’s Form ADV Part 2A $100K-$200K (minimums vary by OSM Manager) No Ambassador RJA and RCS IAR Managed Program Account13 IAR Discretionary or IAR Non- Discretionary13. Yes 2.25% All $25K Margin is generally permitted in IAR Non- discretionary account only In an SMA arrangement, you delegate discretionary investment authority to the SMA Manager. Then the SMA Manager both develops and manages on a discretionary basis the discipline selected by you. In addition to developing the portfolio of securities to invest in, the SMA Manager establishes the trade plan, executes the trades through their selected brokerage firms, and allocates shares/proceeds to client accounts upon completion of the order. Typically, our fixed income disciplines are employed by SMA Managers within the RJCS Program. The RJCS Managers are registered with the SEC, and certain RJCS Managers are affiliated with RJA, including Cougar Global Investments LLC (“Cougar”), Eagle Asset Management, Inc. (“Eagle”), Scout Investments, Inc., who also does business as Reams Asset Management, (“Scout”), ClariVest Asset Management LLC (“ClariVest”), and Chartwell Investment Partners. If you use our Firm and/or our affiliates’ advisory services, we and/or our affiliates receive fees and compensation for management services provided. Please see the “Other Financial Industry Activities and Affiliations” and “Affiliated Managers and Funds” sections for additional information regarding our affiliated Managers and ways we address conflicts associated with the receipt of these fees. In addition, AMS through RJA typically receives sponsorship fees from Managers when AMS sponsors client events and symposiums and/or other regional events. Please refer to the “Receipt of Compensation from Product Sponsors” section for additional information. Certain Managers may invest a portion of your account, or include an allocation within their Model Portfolio, in mutual funds and/or ETFs affiliated with the Manager. Please refer to the “Manager Funds and Manager-Affiliated ETFs” section for additional information. If an SMA Manager elects to use a broker-dealer other than our Firm to effect a transaction in a recommended security (“trade away”), brokerage commissions, and other charges for transactions not effected through us are typically assessed on the trade by the executing broker or dealer and are borne by the client. Please refer to the “SMA Managers that Elect to Trade Away from Raymond James” section for more information. The RJCS Program may not be appropriate for all investors. Since account minimums are typically $100,000 and greater, the RJCS Program may be more appropriate for investors with $300,000 or more to invest. While diversification may be achieved within the RJCS Program, due to portfolio holdings typically numbering between 50 and 100 securities per investment discipline, it is recommended that clients use multiple RJCS Managers with varied investment disciplines (growth, value, large-cap, mid-cap, etc.) to achieve greater diversification. However, clients are not limited in using individual or style specific RJCS Managers as part of their overall portfolio allocation, where additional asset class or investment discipline exposure is addressed in other advisory or brokerage accounts. Diversification and asset allocation do not ensure a profit or protect against a loss. It is important to review your investment objectives, risk tolerance, tax objectives, and liquidity needs before selecting an investment discipline. Please refer to the “Methods of Analysis, Investment Strategies, and Risk of Loss” section for more details. The RJCS Program is typically used by clients that wish to maintain greater control over asset allocation. Your assets are segregated from the assets of other investors (that is, you directly own the portfolio securities versus a mutual fund investor owning shares in an investment company that in turn owns the “pooled” investments). However, there are some RJCS Managers in the Program that hold “pooled” investments. Please refer to the “Manager Funds and Manager-Affiliated ETFs” section for additional information. There is also a discipline offered by our affiliate, Eagle, that employs undertaking for investment collective trusts (“UCITS”) and its eligibility is restricted to only non-U.S. person clients. A list of participating RJCS Managers and available investment disciplines may be requested from your financial advisor. AMS may offer additional disciplines in the future, discontinue previously offered disciplines and may add or remove RJCS Managers at any time. Raymond James Multiple Discipline Account (“MDA”) Program (AMS Managed Program) Within the MDA Program, you can select a broad investment strategy developed by a Manager that employs multiple investment disciplines offered by that Manager in a single account. Each strategy is comprised of a distinct portfolio of securities recommended by the Manager and the allocation to each discipline within a strategy is determined by the Manager. An MDA account offers you an investment solution that allows the Manager to tactically allocate a percentage of the account’s assets into predefined investment disciplines or market sectors (thereby creating a turnkey approach to asset allocation and investment selection). As sponsor of the MDA program, we enter into a subadvisory agreement with select Managers (referred to as “MDA Managers” in this section), which includes affiliated MDA Managers. Please see the “Other Financial Industry Activities and Affiliations” and “Affiliated Managers and Funds” sections for additional information regarding our affiliated Managers and ways we address conflicts associated with the receipt of fees. MDA Managers also participate in the RJCS Program. While MDA Managers are able to offer multiple disciplines in a single account strategy, RJCS Managers are only able to offer a single discipline within a single account. A discipline used in an account strategy by an MDA Manager may not be available as an individual discipline within the RJCS Program. The MDA Manager, similar to an RJCS Model Manager, will typically supply us with their model portfolio for which we will be responsible for organizing and effecting portfolio trades on a discretionary basis. In certain cases, MDA Managers offering strategies that invest in individual corporate or municipal debt securities rather than ETFs for the fixed income allocation retain investment discretion over the entire strategy, including any portion of the strategy allocated to equity disciplines. In these cases, the MDA Manager will typically direct their equity trades through us and direct their fixed income program trades to other broker-dealers. Please refer to the “Third-Party Managers that Elect To Trade Away from Raymond James” section for additional information regarding trades executed away from us and the additional costs that can be incurred. The MDA Manager or AMS, on behalf of RJA, invests the assets in the account on a discretionary basis according to stated selected strategy without soliciting your consent prior to effecting portfolio transactions. The MDA Program may not be appropriate for all investors. MDA accounts may be more appropriate for investors with $300,000 or more to invest. While the MDA Program provides diversification within a strategy, this diversification does not ensure a profit or protect against a loss. It is important to review your investment objectives, risk tolerance, tax objectives, and liquidity needs before selecting an investment strategy. MDA strategies may use exchange-traded fund (ETF) disciplines. Advisory fees charged for the management of your account are in addition to annual management fees, operating expenses and other expenses associated with an investment in ETFs. Please refer to the “Additional Expenses” and “Investment Costs” sections for more information. A list of participating MDA Managers and available strategies may be requested from your financial advisor. AMS may offer additional strategies in the future, discontinue previously offered strategies, and may add or remove MDA Managers at any time. Raymond James Research Portfolios (“RJRP”) Program (AMS Managed Program) The RJRP Program offers certain investment disciplines developed by the AMS Investment Committee. AMS establishes the respective target allocations and selects and monitors investments in the disciplines. You select a compatible investment discipline and AMS assumes discretionary management duties in accordance with the investment discipline. The RJRP Program is typically used by clients that are seeking an opportunity to select an investment discipline that leverages the research services of RJA Equity Research within an AMS Managed account. Portfolios developed for the RJRP Program use fundamental and quantitative analysis, including internal and external research sources. Each portfolio offers a diversified portfolio of securities designed for long-term capital appreciation, to generate current income through dividends, or a combination of both. Portfolios are not typically rebalanced at regular intervals. Instead, the accounts are rebalanced as portfolio changes occur or as part of a comprehensive sector or attribution review performed by AMS. The RJRP Program may not be appropriate for all investors. The RJRP Program may be more appropriate for investors with $100,000 or more to invest. While the RJRP program provides diversification across numerous equity securities within a discipline, this diversification does not ensure a profit or protect against a loss. It is important to review your investment objectives, risk tolerance, tax objectives, and liquidity needs before selecting an investment discipline. A list of disciplines and additional information regarding the investment objectives and portfolio characteristics of each discipline are available through your financial advisor. The AMS Investment Committee may develop and offer additional disciplines in the future, discontinue previously offered disciplines, or modify the target allocations of the disciplines at any time. RJA through a sub-advisory relationship, also provides an RJRP investment strategy to First Trust Advisors L.P. (“First Trust”), an SEC registered investment advisor, for their implementation in the First Trust Raymond James Multicap Growth Equity Exchange Traded Fund (FT-ETF), ticker symbol RJMG. The FT-ETF and related conflicts of interest are further described in the “Compensation Associated with FT-ETF Sub-Advisory Services” and the “ETF Sub-Advisory Services” sections below. Raymond James Freedom Unified Managed Account (“Freedom UMA”) Program (AMS Managed Program) The Freedom UMA Program offers a number of investment strategies. AMS develops the strategies and respective target allocations, and selects and monitors portfolio managers, mutual funds, and exchange traded funds in the strategies. Depending on the strategy you select, your portfolio may include mutual funds and/or ETFs (“Funds”), and “model portfolios” as described below, offered by select affiliated or unaffiliated Model Managers registered with the SEC, with whom RJA has entered into a subadvisory agreement (referred to as “Freedom UMA Managers” in this section). Please see the “Other Financial Industry Activities and Affiliations” and “Affiliated Managers and Funds” sections for additional information regarding our affiliated Managers and affiliated mutual funds and associated compensation arrangements and the ways we address conflicts of interest associated with these relationships and our receipt of fees. The Freedom UMA Program is different from the Freedom Program in that Freedom UMA Managers (as defined below), and not just Funds, are also used through the strategies. The Freedom UMA Managers provide AMS model portfolios comprised of securities recommended by the Freedom UMA Manager for designated investment disciplines, and thereafter will communicate periodic updates to AMS as changes occur to such model portfolios. We have discretionary investment authority in this Program to select Freedom UMA Managers and Funds in constructing the available investment strategies and will effect purchases and sales of model portfolio securities when strategies using these disciplines are selected by you. AMS will annually rebalance your account, based on the anniversary date of its establishment, if at such time the actual asset allocation varies by more than certain predetermined percentages from the target allocation, as established by AMS. You may also request that AMS rebalance your account more frequently, or you may opt out of the annual rebalance. Role of AMS Investment Committee in Developing the Strategies The AMS Investment Committee develops forward-looking risk, return, and correlation assumptions for different asset classes (domestic and international equities, fixed income, real estate, commodities, and other alternative investments) and investment styles (growth, value, market capitalization) with the purpose of expanding portfolio construction considerations beyond an analysis focused solely on historical performance. Once asset allocations have been developed across a broad array of risk and return combinations, where the operating assumption is that risk must be increased in order to increase the potential for higher returns, the AMS Investment Committee optimizes (or adjusts) the allocations in an effort to maximize the expected returns at each pre-established risk level. Having formally established the asset allocation, the AMS Investment Committee then chooses multiple Freedom UMA Manager investment disciplines and/or Funds to invest that portion of the allocation that the AMS Investment Committee believes best aligns with the identified asset class. For example, if the allocation has a 10% weighting to large capitalization domestic equity, the AMS Investment Committee selects an investment discipline of one or more Freedom UMA Managers and/or Funds focused on large-cap domestic equities. Like the Freedom Program, the AMS Investment Committee typically makes a Fund selection when it believes an allocation to a Freedom UMA Manager would be impractical due to the relatively small allocation percentage or asset class fit, such as alternatives/commodities, fixed income, international, and small- to mid-cap- oriented sectors. For example, a Fund may be selected instead of a Freedom UMA Manager to fill the allocation if the amount being invested in the asset class could not be economically invested in the Freedom UMA Manager’s model portfolio (which may be comprised of 100+ individual securities holdings), or if the asset class itself is not available due to capacity constraints (such as liquidity in small-cap and international securities), diversification constraints (such as fixed income minimum investments), and/or general availability (such as alternatives/commodities). Once the allocations have been optimized and populated with select Freedom UMA Manager disciplines and/or Funds, the investment strategies (each a “strategy” or collectively, the ”strategies”) offered are regularly monitored by the AMS Investment Committee and modified as its capital markets outlook and/or opinions of Freedom UMA Managers, Funds, and investment disciplines change, as necessary. Also like the Freedom Program, the AMS Investment Committee develops the strategies and respective target allocations (as further described below) and uses the AMS Manager Research and Due Diligence team (“Manager Research”) for inform its decisions. Strategies may include “Highly Recommended” mutual funds from the Raymond James Mutual Fund Research coverage list. However, the AMS Investment Committee is under no obligation to select mutual funds exclusively from the Raymond James Mutual Fund Research’s “Highly Recommended” list. The AMS Investment Committee then chooses how your account assets are allocated to the various Freedom UMA Managers and/or Funds available within each portfolio. Funds are purchased at net asset value (“NAV”) (without sales charges or commissions). For mutual funds selected by the AMS Investment Committee that are not covered by Mutual Fund Research, it is reasonably likely that Mutual Fund Research will at some point in the future assume research coverage of the mutual fund(s), and that those mutual funds may ultimately be rated “Recommended”. The AMS Investment Committee only considers for potential investment those mutual funds with which we have entered into a selling agreement with the fund company managing or distributing the mutual fund, and even then, the AMS Investment Committee may favor certain share classes over others available under that selling agreement. Please refer to the “Certain Fund Arrangements and Fund- Related Compensation” section for more information. Strategies have been constructed by the AMS Investment Committee to offer an alternative allocation comprised exclusively of non-affiliated Managers. If you select a strategy that uses an affiliated Manager, our affiliates will receive fees and compensation for model management services provided. In addition, we receive marketing and education support payments for providing marketing and other sales support services to affiliated and unaffiliated product sponsors including mutual fund companies, related to their products. As a result of the marketing and education support payments we receive from mutual fund companies, we are incentivized to recommend mutual funds over ETFs in certain strategies within the Freedom UMA Program. Please refer to the “Education & Marketing Support Fees” section for additional information. We invest and reinvest the assets of each account in the appropriate model portfolio investment discipline and/or Funds or other property of any kind as we deem to be in your best interest, in order to achieve your selected investment objective(s). This is done without regard to holding period, portfolio turnover, or resulting gain or loss. While strategies are generally comprised of either equities, including those comprising model portfolios provided by Freedom UMA Managers, or Funds, we may decide to invest a certain portion of the account in other types of securities to maintain trading flexibility and/or market exposure, or to enhance diversification. For example, the AMS Investment Committee may determine that a Fund should be replaced but may not have an immediate replacement Fund candidate. In this case, the AMS Investment Committee may elect to redeem the current Fund in its entirety and invest the proceeds in another investment until a new replacement Fund(s) is selected or may elect to invest in another investment if it believes doing so would potentially enhance the diversification within a given strategy. If the AMS Investment Committee changes its opinion of an investment in a Freedom UMA Manager’s discipline or Fund such that it no longer recommends it as an investment within a given strategy, we reserve the right to remove and/or replace the Freedom UMA Manager’s discipline, Fund, or other security with another investment without your prior consent. You may revoke this authorization at any time by providing instructions to us of your desire to choose another strategy (or Program) or terminate your participation in the respective Freedom UMA Program outright. The Freedom UMA Program may not be appropriate for all investors. The Freedom UMA Program may be more appropriate for investors with $300,000 or more to invest. A client investing only the minimum amount will generally receive a less diversified portfolio than a client investing an amount that would qualify for a more diversified portfolio, based on pre-established minimums. Other investment strategy allocations may be available, where each investment threshold represents the opportunity to access additional Managers and the potential for additional diversification. The Freedom UMA Program is typically used by investors who are seeking the ability to maintain greater control over asset allocation and the ability to use multiple investments to diversify their portfolio in a single combined account. However, asset allocation and diversification does not ensure a profit or protect against a loss. It is important to review your investment objectives, risk tolerance, tax objectives, and liquidity needs before selecting an investment strategy. A list of available strategies and allocation options may be requested from your financial advisor. We do not offer or recommend the full spectrum of Managers available throughout the financial services industry. All of the selected Freedom UMA Managers are also available through the RJCS Program. While a wide array of Freedom UMA Managers and investment disciplines are available, these offerings are limited to those Freedom UMA Managers that agree to participate at the negotiated terms of the subadvisory agreement. Advisory fees charged for the management of your account are in addition to annual management fees, operating expenses and distribution fees assessed by Funds. Please refer to the “Additional Expenses” and “Investment Costs” sections for more information. Portfolio Select Unified Managed Accounts (“Portfolio Select UMA”) Program (AMS Managed Program) The Portfolio Select UMA Program offers a unified managed account comprised of numerous investment options across multiple managed account Programs, as well as mutual funds and exchange traded funds, (collectively, “Funds”). The customized Portfolio Select UMA Program will be allocated among at least two of the following investment categories (a “Portfolio”), subject to certain allocation rules applied to each Portfolio: (i) individual Funds; (ii) strategies selected from our Fund wrap programs; (iii) model portfolios, offered by select affiliated and unaffiliated Managers, (iv) equity research portfolio disciplines developed by AMS or other divisions of RJA; and (v) cash or money market funds for cash management purposes. Please see the “Other Financial Industry Activities and Affiliations” and “Affiliated Managers and Funds” sections for additional information regarding our affiliated Managers and affiliated mutual funds and associated compensation arrangements and the ways we address conflicts of interest associated with these relationships and our receipt of fees. The Portfolio Select UMA Program is offered as an IAR Discretionary Program or as an IAR Non-Discretionary Program. In the Portfolio Select UMA IAR Non-Discretionary Program, your financial advisor assists you, on a non-discretionary basis, in constructing a portfolio from different investment options with the final selections consented to by you. In the Portfolio Select UMA IAR Discretionary Program, your financial advisor has portfolio selection discretion to build a customized portfolio choosing from the different investment options on your behalf; your portfolio summary will be confirmed to you in a notice. In both of the Portfolio Select UMA Programs, AMS has discretion in determining the strategies and Manager disciplines available as investment options and also exercises discretionary authority in investing your account in the investment products you or your IAR have selected and manages the model portfolios as subadviser. Unless you opt out, your Portfolio will be rebalanced annually, based on the anniversary date of its establishment, if at such time the actual asset allocation varies by more than certain predetermined percentages from the target allocation, as established by AMS. Your Portfolio may be rebalanced more frequently, upon your request. Certain limitations apply to the investment categories of the Portfolio Select UMA Program as described below: (i) Funds You can choose between 15 and 40 Funds from an expansive selection of offerings across investment styles and asset classes. Funds available for selection in the Program are of the type designated for use in other fee-based account Programs. (ii) Fund Wrap Program Strategies You may choose several strategies and respective target allocations in the Portfolio is comprised of: (i) Funds available through the Freedom Program, which may include Funds affiliated with RJA; (ii) Fund strategies available through the American Funds Program; (iii) Fund strategies available through the Russell Investments Program. You can learn more about the strategies available in each Fund wrap Program and account investment minimums by visiting the Overview of our Advisory Programs chart or relevant Program description page of this Brochure. (iii) Manager Disciplines At the time the Portfolio Select UMA Program is established and before management of your account commences, at least two thirds of your assets in the customized Portfolio must be invested in investment disciplines offered by Model Managers available through the RJCS Program. Model manager portfolios available within Portfolio Select UMA have minimum investment requirements starting at $100,000. The available Model Managers will maintain the model portfolio and will supply their recommendations to AMS. In turn, AMS, on behalf of RJA, exercises investment discretion in placing trades in your account to conform to the model portfolio and is ultimately responsible for organizing and effecting the portfolio trades. The Model Manager provides advice to AMS. AMS, not the Model Manager solely provides investment advice to you. Thereafter, the Model Manager communicates periodic updates to the model portfolio to AMS. The model portfolio and subsequent updates provided to AMS by the Model Manager is not based on the circumstances of or otherwise tailored to any individual client by the Model Manager. You can learn more about the disciplines available for each Model Manager Program and account investment minimums by visiting the Overview of our Fee Wrap Programs chart or relevant Program description page of this Brochure. (iv) Equity Research Portfolio Disciplines In your customized Portfolio, you have access to certain equity research disciplines developed by the AMS Investment Committee based on research provided by the Equity Capital Markets (“ECM”) division. AMS establishes the respective target allocations, and selects and monitors investments in the disciplines, which are currently offered through the RJRP Program. You can learn more about the disciplines available and account investment minimums by visiting the Overview of our Programs chart or relevant Program description page of this Brochure. (v) Cash Your customized Portfolio can hold up to 15% in cash or money market funds for cash management purposes and can accommodate cash and cash alternatives assets at this maximum level, which is evaluated at the time of account opening and at rebalancing. Due to account value fluctuations, cash holdings may be higher than 15% of the overall account value prior to rebalancing. In the Portfolio Select UMA, unlike the Freedom UMA Program, your financial advisor assists you in developing the target allocations and portfolio composition, not the AMS Investment Committee. Your financial advisor will assist you in developing an appropriate asset class allocation and build the customized Portfolio choosing from the investment products within each asset class identified. You will agree to the initial (i) composition of the Portfolio and (ii) allocation of investments across the asset classes, as represented on the Investment Strategy Selection Form and any ongoing recommendations for your Portfolio. Once completed, your Portfolio will be delivered by your financial advisor to AMS for implementation. If your financial advisor recommends a change to the composition of the Portfolio or allocation of investments across the asset classes, we will obtain your authorization prior to doing so. Because the Portfolio Select UMA Program is a discretionary program, we have authority under the advisory agreement, which may include the Master Advisory Agreement, to invest and reinvest the assets of each Portfolio Select account in the appropriate security, asset, or other property of any kind as we deem to be in your best interest, in order to achieve your selected investment objective(s). This is done without regard to holding period, portfolio turnover, or resulting gain or loss. RJA only considers for potential investment those mutual funds with which we have entered into a selling agreement with the fund company managing or distributing the mutual fund and may favor certain share classes over others available under that selling agreement. Please refer to the “Certain Fund Arrangements and Fund-Related Compensation” section for more information. There are investment strategies or disciplines within each advisory account program that do not contain affiliated funds, and you may select a strategy or discipline that does not invest in affiliated funds. Tax-qualified retirement accounts are not eligible to invest in affiliated mutual funds, as federal regulations prohibit affiliated mutual funds from being purchased in tax-qualified retirement advisory accounts. In addition, we receive marketing and education support payments for providing marketing and other sales support services to affiliated and unaffiliated product sponsors, including mutual fund companies related to their products. As a result of the marketing and education support payments we receive from mutual fund companies, we are incentivized to recommend mutual funds and to allocate more assets to mutual funds than SMA Manager Disciplines when recommending the asset allocation. Please refer to the “Education & Marketing Support Fees” section for additional information. Certain Managers may invest a portion of your account, or include an allocation within their Model Portfolio, in mutual funds and/or ETFs affiliated with the Manager. Please refer to the “Manager Funds and Manager-Affiliated ETFs” section for additional information. The Portfolio Select UMA Program may not be appropriate for all investors. The Portfolio Select UMA Program may be more appropriate for investors with $300,000 or more to invest. The Portfolio Select UMA Program is typically used by investors who are seeking the ability to maintain greater control over asset allocation and the ability to use multiple investments to diversify their portfolio in a single combined account in lieu of separate accounts. However, asset allocation and diversification does not ensure a profit or protect against a loss. It is important to review your investment objectives, risk tolerance, tax objectives, and liquidity needs before selecting an investment strategy. We do not offer or recommend the full spectrum of Funds, Managers, disciplines, and strategies available throughout the financial services industry. A list of available strategies, Funds, Managers, disciplines, and allocation options may be requested from your financial advisor. The investment products selected by you represent only a fraction of the offerings available to you. Many of the investment products, including certain Funds, strategies, disciplines, and Managers available in the Portfolio Select UMA Program are available in the other RJA wrap fee Programs referenced. RJA may develop and offer additional strategies, disciplines, Managers, Funds or discontinue previously offered strategies, disciplines, Managers or Funds in the future, disciplines or strategies may increase or decrease the minimum investment and will likely modify the target allocations of certain Fund Wrap Program strategies in the future. Further information on the portfolio manager(s), investment objectives, risks, charges, fees, including short-term redemption fees, expenses and other details for the Funds selected for the portfolios is available by prospectus, which may be obtained from your financial advisor. Advisory fees charged for the management of your account are in addition to annual management fees, operating expenses and distribution fees assessed by Funds. Please refer to the “Additional Expenses” and “Investment Costs” sections for more information. Raymond James Freedom Account (“Freedom”) Program (AMS Managed Program) In the Freedom Program, AMS constructs multiple investment strategies consisting of mutual funds and/or ETFs (collectively, “Funds”) that represent a broad array of asset classes and investment styles. AMS develops the strategies, establishes the respective target allocations, and selects and monitors the Fund investments in the strategies. You select a compatible investment strategy, with the assistance of your financial advisor. Unlike the Freedom UMA Program, the Freedom Program does not also include asset allocations to Managers. Strategies are developed by the AMS Investment Committee and may include “Highly Recommended” mutual funds from the Raymond James Mutual Fund Research coverage list. However, the AMS Investment Committee is under no obligation to select mutual funds exclusively from Mutual Fund Research’s “Highly Recommended” list. Within the Freedom Program, we offer mutual fund, ETF, hybrid, foundation, completion portfolio, environmental, social and governance strategies, and retirement income solution strategies. The AMS Investment Committee manages the selection and allocations among the various Funds available in your chosen strategy/strategies. Mutual funds are purchased at NAV (without sales charges or commissions). The target allocation for each of the model portfolios applies at the time you establish a Freedom Program account. AMS will annually rebalance your account, based on the anniversary date of its establishment, if at such time the actual asset allocation varies by more than certain predetermined percentages from the target allocation, as established by AMS. You may also request that AMS rebalance the account more frequently, or you may opt out of the annual rebalance. Role of AMS Investment Committee in Developing the Strategies Like the Freedom UMA Program, the AMS Investment Committee develops forward-looking risk, return, and correlation assumptions for different asset classes (domestic and international equities, fixed income, real estate, commodities, and other alternative investments) and investment styles (growth, value, market capitalization) with the purpose of expanding portfolio construction considerations beyond an analysis focused solely on historical performance. Once asset allocations have been developed across a broad array of risk and return combinations, where the operating assumption is that risk must be increased in order to increase the potential for higher returns, the AMS Investment Committee optimizes (or adjusts) the allocations in an effort to maximize the expected returns at each pre-established risk level. Having formally established the asset allocation for each strategy, the AMS Investment Committee then selects multiple Funds to invest that portion of the allocation that the AMS Investment Committee believes best aligns with the identified asset class. For example, if the allocation has a 10% weighting to large capitalization domestic equity, the AMS Investment Committee will select a Fund focused on large-cap domestic equities. Once the allocations have been optimized and populated with select Fund disciplines, the investment strategies offered are regularly monitored by the AMS Investment Committee and modified as its capital markets outlook and/or opinions of Funds and their related investment disciplines change, as necessary. The AMS Investment Committee may find occasion to invest in a mutual fund with a relatively low level of assets under management. Depending on the total investment in the fund, Freedom accounts may collectively become a significant or majority shareholder of the fund. If the AMS Investment Committee determines a program-wide or cross-program redemption is warranted, this could result in potential redemption delays for the fund such as the fund’s inability to quickly liquidate holdings. The AMS Investment Committee endeavors to minimize the market impact of any investment related decisions that it makes. AMS develops the strategies and the respective target allocations and uses Manager Research to inform its investment decisions. For mutual funds selected by the AMS Investment Committee that are not covered by Mutual Fund Research, it is reasonably likely that Mutual Fund Research will at some point in the future assume research coverage of the mutual fund(s), and that those mutual funds may ultimately be rated “Recommended”. The AMS Investment Committee only considers for potential investment those mutual funds with which we have entered into a selling agreement with the fund company managing or distributing the mutual fund and may favor certain share classes over others available under that selling agreement. In addition, we have selling agreements with fund companies that are affiliated with Raymond James. In most cases, you can choose strategies that do not include affiliated mutual funds, as in general, strategies have been constructed by the AMS Investment Committee to offer an alternative allocation comprised exclusively of non-affiliated mutual funds. Tax-qualified retirement accounts are automatically invested in the selected investment strategy that does not invest in affiliated mutual funds, as federal regulations prohibit affiliated mutual funds from being purchased in tax-qualified retirement advisory Program accounts. For non-retirement accounts, if no selection is made, the default is to use affiliated mutual funds in certain investment strategies, where applicable. If you use a strategy that uses mutual funds of one of our affiliates, our affiliates will receive fees and compensation for management services provided to the fund. Please also refer to the “Other Financial Industry Activities and Affiliations” and “Affiliated Managers and Funds” sections for additional information regarding affiliated mutual funds and the “Certain Fund Arrangements and Fund-Related Compensation” section for additional information regarding mutual funds available for investment through us, associated compensation arrangements, conflicts of interest associated with these relationships and the way we address conflicts of interest associated with the receipt of these fees. In addition, we receive marketing and education support payments for providing marketing and other sales support services to affiliated and unaffiliated mutual fund companies related to their funds. As a result of the marketing and education support payments we receive from mutual fund companies, we are incentivized to recommend mutual fund strategies over ETF strategies and to allocate more assets to mutual funds than ETFs when developing the asset allocation models for our hybrid strategies. Please refer to the “Education & Marketing Support Fees” section for additional information. Because the Freedom Program is a discretionary program, we have authority under the Freedom advisory agreement to invest and reinvest the assets of each Freedom account in the appropriate Funds or other property of any kind as we deem to be in your best interest, in order to achieve your selected investment objective(s). This is done without regard to holding period, portfolio turnover, or resulting gain or loss. While strategies are generally comprised of Funds, we may decide to invest a certain portion of the account in alternative securities to maintain trading flexibility and/or market exposure, or to enhance diversification. For example, the AMS Investment Committee may determine that a Fund should be replaced but may not have an immediate replacement candidate. In this case, the AMS Investment Committee may elect to redeem the current Fund in its entirety and invest the proceeds in another investment if it believes doing so would potentially enhance the diversification within a given strategy. If the AMS Investment Committee changes its opinion of an investment in a Fund, such that it no longer recommends it as an investment within a given strategy, we reserve the right to remove and/or replace the Fund or other security with another investment without your prior consent. You may revoke this authorization at any time by providing instructions to us of your desire to choose another strategy (or Program) or terminate your participation in the Freedom Program outright. The Freedom Program may not be appropriate for all investors. Funds have unique distinguishing characteristics and their cost structures differ, sometimes significantly. Advisory fees charged for the management of your account are in addition to annual management fees, operating expenses and distribution fees assessed by Funds. Please refer to the “Additional Expenses” and “Investment Costs” sections for more information. The Freedom Program may be appropriate for a client who is interested in an account that offers multiple asset allocation strategies, automatic fund selection, and annual rebalancing. Asset allocation and diversification does not ensure a profit or protect against a loss. It is important to review your investment objectives, risk tolerance, tax objectives, and liquidity needs before selecting an investment strategy and allocation options. Mutual fund strategies reinvest dividends and capital gains if you do not provide instructions to hold these payments in cash. Please contact your financial advisor if you would like to elect or change a reinvestment option. You can also elect to receive withdrawals from your account on a periodic basis (e.g., systematic withdrawal or payment options). Please refer to the Disbursement/Withdrawal Requests section for more information. We do not offer or recommend the full spectrum of Funds available throughout the financial services industry. A list of available strategies, Funds, and target allocations for these programs may be requested from your financial advisor. The AMS Investment Committee may develop and offer additional strategies or discontinue previously offered strategies in the future, will add or remove Funds, may increase or decrease the minimum investment, and will likely modify the target allocations of the strategies in the future. Further information on the portfolio manager(s), investment objectives, risks, charges and expenses and other details for the Funds selected for the Freedom portfolios is available by prospectus, which may be obtained from your financial advisor. American Funds Model Portfolios (“American Funds”) Program (AMS Managed Program) The American Funds Program is an asset allocation-based mutual fund investment program that provides clients access to mutual fund model portfolios delivered to us by Capital Research and Management Company (“Capital Research”). Capital Research develops the model portfolio asset allocation and selects the underlying open-end mutual funds of their American Funds affiliate populating each model portfolio, and thereafter communicates periodic updates to AMS as changes occur to the model portfolios. We have entered into a subadvisory agreement with Capital Research where Capital Research provides non-discretionary advice to us with respect to the asset allocation and fund composition of each model portfolio. Capital Research also manages the American Funds mutual funds. To implement the model portfolios, you appoint us to manage your account on a discretionary basis with the full power to buy, exchange, and/or sell American Funds mutual funds based on the predetermined models provided to us by Capital Research. The model portfolios offered in the American Funds Program consist exclusively of allocations to American Funds, which are purchased at NAV (without sales charges or commissions), and no other funds or investments are considered in the composition of any the model portfolios. Based upon your financial needs, risk tolerances, and investment objectives, your financial advisor assists you in selecting the appropriate model portfolio. While we retain the ultimate decision-making authority and investment discretion over all accounts participating in the American Funds Program, we generally expect to implement the majority of, if not all, asset allocation and/or fund changes applicable to one or multiple model portfolios as recommended by Capital Research. In the American Funds Program, we provide all investment advice to you relating to the American Funds Program. Capital Research communicates periodic updates to AMS as changes occur to the model portfolios. Model portfolio recommendations provided by Capital Research to us are not based on the circumstances of or otherwise tailored to any individual client. Capital Research receives compensation from the American Funds that comprise the model portfolios provided to us (via the management fee applicable to each fund) and is not compensated under the subadvisory agreement or as part of the asset-based fee assessed by us to your account. The target allocation for each of the model portfolios applies at the time you establish an American Funds Program account. Additions to and withdrawals from an account are generally invested based on the target allocation. Fluctuations in the market value of securities, as well as other factors, however, affect the actual asset allocation at any given time. On an annual basis, we rebalance your account, based on the anniversary date of its establishment, if at such time the actual asset allocation varies by more than certain predetermined percentages from the target allocation, as established by AMS. We may also rebalance your account upon your request, or you may opt out of the annual rebalance. Capital Research reserves the right to modify the target allocation of each model portfolio based on changes to its capital markets outlook. We receive marketing and education support payments for providing marketing and other sales support services to affiliated and unaffiliated mutual fund companies related to their funds, including American Funds. Please refer to the “Education & Marketing Support Fees” section for additional information. Advisory fees charged for the management of your account are in addition to annual management fees, operating expenses and distribution fees assessed by mutual funds. Please refer to the “Additional Expenses” and “Investment Costs” sections for more information. The American Funds Program may not be appropriate for all investors. Mutual funds have unique distinguishing characteristics and their cost structures differ, sometimes significantly. Please refer to the “Investment Costs” sections for more information. Diversification and asset allocation do not ensure a profit or protect against a loss. It is important to review your investment objectives, risk tolerance, tax objectives, and liquidity needs before selecting an investment strategy. The American Funds Program may be appropriate for a client who is interested in an account that offers multiple asset allocation strategies, automatic fund selection, and annual rebalancing. Mutual fund strategies reinvest dividends and capital gains if you do not provide instructions to hold these payments in cash. Please contact your financial advisor if you would like to elect or change a reinvestment option. You can also elect to receive withdrawals from your account on a periodic basis (e.g., systematic withdrawal or payment options). Please refer to the “Disbursement/Withdrawal Requests” section for more information. As sponsor of the American Funds Program, we do not offer or recommend the full spectrum of American Funds models that may be available through firms that sponsor programs similar to the American Funds Program offered through us. A list of current model strategies and the applicable target allocations may be requested from your financial advisor. Additional information regarding a mutual fund’s portfolio manager(s), investment objectives, risks, charges and expenses and other details is available in the American Funds’ prospectus, which may be obtained from your financial advisor. Russell Investments Model Strategies (“Russell”) Program (AMS Managed Program) The Russell Program is an asset-based mutual fund investment program that provides clients access to mutual fund model portfolios developed by Russell Investments that consist exclusively of mutual funds advised by the Russell Investments Company (“Russell Investments”). Russell Investments develops the model portfolio asset allocation and selects the underlying Russell Investments mutual funds populating each model portfolio, and thereafter communicates periodic updates to AMS as changes occur to such model portfolios. To implement the model portfolios, you appoint AMS to manage your account on a discretionary basis with the full power to buy, exchange, and/or sell Russell Investments’ mutual fund shares in the predetermined models provided to us by Russell Investments. The model portfolios offered in the Russell Program consist exclusively of allocations to Russell Investments mutual funds, which are no-load mutual funds purchased at NAV (without sales charges or commissions), and no other funds or investments are considered in the composition of any of the model portfolios. Through our agreement with Russell Investments, Russell Investments provides non-discretionary advice to us concerning the asset allocation and fund composition of each model portfolio. Russell Investments evaluates and retains investment management firms (“Portfolio Managers”) to manage each Russell Investments mutual fund used in the model portfolios. Portfolio Managers may be terminated or replaced by Russell Investments generally as a result of changes in senior investment personnel, relative underperformance, or a deviation or change in the Portfolio Manager’s investment discipline. Portfolio Manager changes initiated by Russell Investments do not result in transactions being effected by AMS, and changes are effected without prior notice to you. Russell Investments exercises investment discretion over the allocation of assets to each Portfolio Manager and may elect to not allocate management duties for a portion of a Russell Investments mutual fund’s assets to any Portfolio Manager. Russell Investments may also manage portions of a Russell Investments mutual fund during transition periods between Portfolio Manager allocations. Based upon your financial needs, risk tolerances, and investment objectives, your financial advisor assists you in selecting the appropriate model portfolio. However, even though we retain the ultimate decision-making authority and investment discretion over all accounts participating in the Russell Program, we generally expect to implement the majority of, if not all, asset allocation and/or fund changes applicable to one or multiple model portfolios as recommended by Russell Investments. In the Russell Program, we provide all investment advice to you relating to the Russell Program and model portfolio recommendations provided by Russell Investments to us are not based on the circumstances of or otherwise tailored to any individual client. Russell Investments receives compensation from Russell Funds that comprise the model portfolios provided to us (via the management fee applicable to each fund) and receives no compensation from the asset-based fee assessed by Raymond James to your account. The target allocation for each of the model portfolios applies at the time you establish a Russell Program account. Additions to and withdrawals from an account are generally invested based on the target allocation. Fluctuations in the market value of securities, as well as other factors, however, affect the actual asset allocation at any given time. On an annual basis, we rebalance your account, based on the anniversary date of its establishment, if the actual asset allocation varies by more than certain predetermined percentages from the target allocation, as established by AMS. We may also rebalance an account upon your request, or you may opt out of the annual rebalance. Russell Investments reserves the right to modify the target allocation based on changes to its capital markets outlook. We receive marketing and education support payments for providing marketing and other sales support services to affiliated and unaffiliated mutual fund companies related to their funds, including from Russell Investments. Please refer to the “Education & Marketing Support Fees” section for additional information. Advisory fees charged for the management of your account are in addition to annual management fees, operating expenses and distribution fees assessed by mutual funds. Please refer to the “Additional Expenses” and “Investment Costs” sections for more information. The Russell Program may not be appropriate for all investors. Mutual funds have unique distinguishing characteristics and their cost structures differ, sometimes significantly. Please refer to the “Investment Costs” sections for more information. Diversification and asset allocation do not ensure a profit or protect against a loss. It is important to review your investment objectives, risk tolerance, tax objectives, and liquidity needs before selecting an investment strategy. A Russell Program may be appropriate for a client who is interested in an account that offers multiple asset allocation strategies, automatic fund selection, and annual rebalancing. Mutual fund strategies reinvest dividends and capital gains if you do not provide instructions to hold these payments in cash. Please contact your financial advisor if you would like to elect or change a reinvestment option. You can also elect to receive withdrawals from your account on a periodic basis (e.g., systematic withdrawal or payment options). Please refer to the Disbursement/Withdrawal Requests section for more information. As sponsor of the Russell Program, we do not offer or recommend the full spectrum of Russell model portfolios that may be available through firms that sponsor programs similar to the Russell Program. A list of current model strategies and the applicable target allocations may be requested from your financial advisor. Additional information regarding the mutual funds' Portfolio Managers, investment objectives, risks, charges and expenses, and other details is available in the Russell funds’ prospectus, which may be obtained from your financial advisor. BlackRock Model Portfolios (“BlackRock”) Program (AMS Managed Program) The BlackRock Program is an asset allocation-based investment program investing exclusively in Undertakings for Collective Investment in Transferable Securities (“UCITS”) offered and issued by BlackRock Financial Management, Inc. (“BlackRock”) solely to non-U.S. clients under the terms and conditions of the UCITS current prospectus. UCITS are the European regulatory framework for an investment vehicle that can be marketed across the European Union, subject to certain notification and registration requirements. For purposes of this section only, the terms “UCITS funds” and “funds” may be used interchangeably in reference to UCITS. The BlackRock Program provides non-U.S. clients access to UCITS model portfolios delivered to us by BlackRock. BlackRock develops the UCITS model portfolio asset allocation and selects the underlying BlackRock funds affiliate populating each model portfolio, and thereafter communicates periodic updates to AMS as changes occur to the model portfolios. Through our subadvisory agreement with BlackRock, BlackRock provides non-discretionary advice to us with respect to the asset allocation and fund composition of each model portfolio. To implement the model portfolios, you appoint us to manage your account on a discretionary basis with the full authority to buy and/or sell BlackRock UCITS based on the model strategy/strategies you have selected. UCITS shares are bought and sold at market price (not NAV) and are not individually redeemed from the fund. Based upon your financial needs, risk tolerances, and investment objectives, your financial advisor assists you in selecting the appropriate model portfolio. While we retain the ultimate decision-making authority and investment discretion over all accounts participating in the BlackRock Program, we generally expect to implement the majority of, if not all, asset allocation and/or fund changes applicable to one or multiple model portfolios as recommended by BlackRock. In the BlackRock Program, we provide all investment advice to you relating to the BlackRock Program. BlackRock communicates periodic updates to AMS as changes occur to the model portfolios. Model portfolio recommendations provided by BlackRock to us are not based on the circumstances of or otherwise tailored to any individual client. BlackRock receives compensation from the BlackRock UCITS that comprise the model portfolios provided to us (via the management fee applicable to each fund) and is not compensated under the subadvisory agreement or as part of the advisory fee assessed by us to your account. The target allocation for each of the model portfolios applies at the time you establish a BlackRock Program account. Additions to and withdrawals from an account are generally invested based on the target allocation. Fluctuations in the market value of securities, as well as other factors, however, affect the actual asset allocation at any given time. BlackRock uses a quantitative and qualitative process that is implemented periodically during the year so as to decide how to rebalance the portfolio. A variety of indicators, including valuations, momentum, and rotation of style factors, are taken into consideration for the guidance of asset allocation decisions. Macroeconomic tendencies, global news and current market conditions are also taken into account. BlackRock reserves the right to modify the target allocation of each model portfolio based on changes to its capital markets outlook. Advisory fees charged for the management of your account are in addition to annual management fees, operating expenses and distribution fees assessed by BlackRock UCITS. Please refer to the “Additional Expenses” and “Investment Costs” sections for more information. The BlackRock Program may not be appropriate for all eligible investors, is available solely to non-U.S. clients, and is limited to UCITS offered only through BlackRock. UCITS have unique distinguishing characteristics and their cost structures differ, sometimes significantly. Please refer to the “Investment Costs” sections for more information. Diversification and asset allocation do not ensure a profit or protect against a loss. It is important to review your investment objectives, risk tolerance, tax objectives, and liquidity needs before selecting an investment strategy. The BlackRock Program may be appropriate for a client who is interested in an account that offers multiple asset allocation strategies. Dividends and interest are paid in cash. You can also elect to receive withdrawals from your account on a periodic basis (e.g., systematic withdrawal or payment options). Please refer to the “Disbursement/Withdrawal Requests” section for more information. As sponsor of the BlackRock Program, we do not offer or recommend the full spectrum of BlackRock UCITS models that may be available through firms that sponsor programs similar to the BlackRock Program offered through us. A list of current model strategies and the applicable target allocations may be requested from your financial advisor. Additional information regarding an UCITS portfolio manager(s), investment objectives, risks, charges and expenses and other details is available in the BlackRock prospectus, which may be obtained from your financial advisor. Outside Manager (“OSM”) Platform (Dual Contract Platform) In the OSM Platform, investment advisory services are provided to you by two different investment advisers through two advisory contracts (what is referred to as a “Dual Contract”): (1) under your OSM agreement (“OSM Agreement”) your financial advisor will provide non-discretionary advisory services in recommending the OSM Platform and assisting you with selecting a third-party Manager (“OSM Manager”) and a compatible investment discipline available through the OSM Platform, and (2) through a separate investment management agreement between you and the selected OSM Manager (to which Raymond James is not a party), you appoint the OSM Manager to manage the assets of your account on a discretionary basis, which means you delegate the authority to your OSM Manager to decide what securities to buy or sell for your account in accordance with the investment discipline you select. Under the OSM Agreement, your investment adviser (whether RJA, another Raymond James affiliated investment adviser, or an independent investment adviser), through your financial advisor, will provide non-discretionary advisory services. Your financial advisor generally (i) assists you in defining your investment objectives based on information you have provided, (ii) determines whether the given fee arrangement is appropriate, (iii) aids in the selection or retention of an OSM Manager to manage the account (or a portion of its assets, (iv) assists in the allocation of assets between OSM Managers if more than one has been selected, and (v) monitors your account to determine if a change in the Program, OSM Manager, or discipline you previously selected is appropriate. Raymond James’ role is exclusively non-discretionary. The OSM Manager is solely responsible for the management of your account and for providing discretionary investment management services to you. The OSM Manager makes all investment decisions and is solely responsible for those investment decisions. RJA does not have the ability to select investments for purchase or sale within the OSM Platform. RJA will only carry out transactions as instructed by the OSM Manager. RJA, acting as administrator for the OSM Platform, provides various support services, including account opening and maintenance, processing of cash contributions, withdrawal and distribution requests, semiannual monitoring of the OSM Managers, and facilitation of terminations of a client’s participation in the OSM Platform. RJA and/or its affiliates provide custodial and brokerage services, including execution services for trading the OSM Manager elects to do through Raymond James, or settling and allocating trades to accounts when the OSM Manager elects to trade through a firm other than Raymond James. OSM Managers may have alternative arrangements for trade execution under your agreement with that OSM Manager. If the OSM Manager instructs RJA to effect trades through us, you will not be separately charged for brokerage commissions in addition to your Fee charged by us. If the OSM Manager elects to use brokers-dealers other than our Firm to effect a transaction in a recommended security (“trade away”), brokerage commissions and other charges for transactions not effected through us are generally charged to you by the executing broker or dealer. Please refer to the “Additional Expenses” section for more information. OSM Managers are generally registered as investment advisers with the SEC, but in certain cases the OSM Manager is registered instead with its state securities authority. Certain Managers may invest a portion of your account, or include an allocation within their model portfolio, in mutual funds and/or ETFs, some of which may be affiliated with the Manager. Please refer to the “Manager Funds and Manager-Affiliated ETFs” section for additional information. The OSM Manager typically calculates and collects their own management fee. We will debit the OSM Manager’s fee to your account as authorized by you in the OSM Agreement but are not responsible for verification of the fee computation. We may accommodate different billing arrangements for OSM Managers on an exception basis, including OSM Managers that bill in arrears, assess a performance-based fee or bill in advance in equal installments rather than the specific number of days in the billing period, or otherwise may delegate the billing administration to AMS. Certain OSM Managers may be compensated by performance-based fees. In these cases, our Firm and our financial advisors do not receive compensation based on the performance-based fee charged by the OSM Manager. Additional information about the performance-based fee charged can be found in the OSM Manager’s investment management agreement, their Form ADV Part 2A or Wrap Fee Brochure. The investment adviser firm through which your financial advisor provides advisory services has an initial and ongoing obligation to determine the suitability of your participation in the OSM Platform and the investment discipline and OSM Manager selected by you and retains the responsibility to monitor your account(s) and recommend to you if changes should be made to your OSM Platform selection(s). We do not offer the full spectrum of outside managers and investment disciplines available throughout the financial services industry through the OSM Platform. The OSM Platform is typically used to accommodate financial advisors joining our Firm who have clients with pre-existing relationships with an investment manager not otherwise available in our wrap fee programs or with a Manager that is already approved as an OSM Manager. A Manager may be added to the OSM Platform at our discretion, and factors that may be considered include the anticipated demand for the Manager, a prospective client’s request, and the availability of similar investment disciplines through other advisory programs or through alternative investment vehicles such as Funds or alternative investments, among other factors. Ambassador Account (“Ambassador”) Program (IAR Managed Program) Ambassador offers you either discretionary or non-discretionary advisory services provided directly by a financial advisor. Ambassador offers you the opportunity to work with your financial advisor but maintain full investment authority and direct the individual investments made within your account (non-discretionary), or you can authorize your financial advisor to assume full investment authority over your account (discretionary). When you have an Ambassador IAR Discretionary Program Account, your financial advisor must be pre-qualified through our Discretionary Advisor Program (advisor due diligence review process). To learn more about the qualifications we generally require of our financial advisors to be able to offer discretionary account services, please refer to the “Internal Review and Selection of Financial Advisors as Portfolio Managers” section for additional information. If you delegate discretionary authority to RJA, your financial advisor assumes all investment duties on your behalf and exercises discretion with respect to your account. You will not be consulted prior to your financial advisor effecting transactions in your account. If you retain discretionary authority, as you do in an Ambassador IAR Non-Discretionary Program Account, you are responsible for approving which investments and in what quantities are to be purchased or sold in your account. For more information on conflicts of interest associated with your financial advisor providing advisory services and how we address those conflicts, please refer to the “Financial Advisor Compensation” section. If your financial advisor is associated with RJFSA or an independent registered investment adviser firm, your financial advisor and the associated registered investment adviser and not RJA are providing investment advice as to which securities and in what quantities should be purchased or sold. Please refer to the RJFSA Wrap Fee Program Brochure or independent registered investment adviser’s Form ADV Part 2A, as applicable, for additional information. As part of the Ambassador Program, your financial advisor can help you determine your goals and the level of risk that is comfortable for you, assist you in choosing investments, provide you with ongoing investment advice, monitor your securities holdings, rebalance your account, as needed, meet with you periodically to discuss your investments, and learn whether your needs have changed. Your financial advisor provides ongoing services to your account, on a non-discretionary or a discretionary basis, according to your objectives. Please refer to the “Methods of Analysis, Investment Strategies, and Risk of Loss” section for more details. The Ambassador Program may be appropriate for an investor seeking to create or consolidate their investment portfolio within a single account. You can hold a broad range of investments such as mutual funds, exchange traded funds, stocks, bonds, real estate investment trusts, options, and other investments (your financial advisor’s investment adviser may place limitations on what can be bought or sold in an Ambassador account). You have access to periodic statements (“account statements”) provided by the custodian in any month or quarter in which there is activity in your account and reporting tools to help track your investments and investment performance. Accounts in the Ambassador Program are not for day trading or other extreme trading activity, including excessive options trading or trading in mutual funds based on market timing. We reserve the right to terminate, in our sole discretion, any client account in the Ambassador Program that we feel has engaged in or exhibited excessive trading. RJA, through a sub-advisory relationship, also provides a model portfolio based on an RJRP investment strategy to First Trust Advisors L.P. (“First Trust”), an SEC registered investment advisor, for their implementation in the First Trust Raymond James Multicap Growth Equity Exchange Traded Fund (FT-ETF), ticker symbol RJMG. The FT-ETF, which may be purchased in a non-retirement Ambassador account, and related conflicts of interest are further described in the “Compensation Associated with FT-ETF Sub-Advisory Services” and the “ETF Sub-Advisory Services” sections below. We receive marketing and education support payments from affiliated and unaffiliated product sponsors, including mutual fund companies for providing marketing and other sales support services related to their products or services that are made available to you. Please refer to the “Education & Marketing Support Fees” section for additional information. Advisory fees charged for the management of your account are in addition to annual management fees, other fees including short-term redemption fees, operating expenses, and distribution fees assessed by Funds and other investments. Please refer to the “Additional Expenses” and “Investment Costs” sections for more information. Fee-based Annuities RJA financial advisors can make sub-accounts allocation recommendations for various indexed, variable, and structured fee-based annuities (collectively, “fee-based annuities”) available through the Firm on a non-discretionary basis for an advisory fee, subject to the Ambassador Fee Schedule located in the “Standard Fee Schedules for AMS Managed and IAR Managed Programs and Dual Contract Platform” section. You maintain discretionary authority over the selection of the sub-accounts or underlying investment options, which means that your financial advisor must consult with you to obtain your approval as to which sub-accounts/investments are to be purchased or sold in your fee-based annuity. Advisory fees charged for the sub-account/investment allocation recommendations provided for fee-based annuities are in addition to any underlying contract related to the fee-based annuity. You may refer to your fee-based annuity’s prospectus for a description of any underlying contract fees. You should be aware that certain riders purchased with the fee-based annuity may limit the investment options and the ability to reallocate to certain sub-accounts. Additionally, the decision to liquidate a fee-based annuity prior to the end of its surrender charge period may result in early withdrawal charges and a complete loss of certain benefits for which fees may have previously been paid to the annuity company. For variable annuities and certain structured annuities, you should rely solely on the disclosure contained in the annuity contract and the product prospectus with respect to the terms and conditions of the annuity. For details on the provisions of the index annuity, please refer to the annuity contract. Please also refer to the “Additional Expenses” and “Investment Costs” sections for more information. The issuer’s fee-based annuity must be linked to your Ambassador account to effect billing. In order to bill you for investment advice on the fee- based annuity, you will need to maintain a cash balance in your Ambassador account from which your advisory fees can be deducted or provide another non-retirement brokerage account for the advisory fee to be debited. Refer to the “Fee-Billing Practices” section for information about our fee billing practices. Legacy Advisory Programs We have offered or sponsored other advisory programs to clients in the past that we may no longer offer to prospective clients for a variety of reasons. In those cases, active legacy advisory accounts established in those prior investment advisory programs continue to be managed under the pre-existing advisory program agreement. For example, prior to 2004, certain advisory accounts were directly managed by Eagle Asset Management, an affiliated investment adviser and custodied at RJA pursuant to client instruction. Beginning 2004, Eagle retail advisory client accounts were offered to RJA and affiliate, RJFSA through the RJCS platform pursuant to a sub-advisory agreement between the Firm and Eagle. As of January 2015, the Eagle High Net Worth (“EHNW”) program is no longer offered to prospective clients, as the investment disciplines available in EHNW generally became available through the RJCS Program. Advisory Fees In our wrap fee advisory programs described above, you are generally assessed an inclusive wrap fee for advisory and brokerage services. Under a wrap fee arrangement, you pay an annual asset-based fee (the “Fee”), which is calculated as a percentage of assets under management in the account. The Fee includes compensation paid to your financial advisor, the firm he or she is affiliated with, to any affiliated and non- affiliated Manager, and to RJA for trade execution, custodial, trade clearance, investment advisory and administrative services. While the allocation of the Fee may change at any time without your consent, the total Fee percentage charged to your account will not increase above your agreed-to cap rate without your consent. You can incur additional expenses outside of the wrap fee charged to you; more information about those expenses is provided in the “Additional Expenses” section below. We are compensated for the advisory services described in this Brochure. Fees may be negotiated with your financial advisor based on a variety of factors, including the nature and size of your overall relationship with your advisor, anticipated investment services to be provided, anticipated additional execution costs related to the Managers that trade away from us, and/or our affiliates’ policies with respect to discounts. While the Fees are negotiable, the standard fee schedule’s asset-level breakpoints and applicable fee rate may not be modified in any way. An inherent conflict exists in how we handle billing variations from the applicable fee schedule, as compensation arrangements can result in higher gross compensation to the financial advisor from one advisory program over another. You may pay a higher fee than the Fee listed in the standard fee schedule detailed below (but not more than the program’s maximum fee) as a result of fluctuations in your assets under management and/or account performance. For information concerning conflicts of interest created by the Firm and your financial advisor’s compensation and how we mitigate those conflicts of interest, please refer to the “Compensation” section. Employees and our affiliates’ employees may be offered reduced advisory fees for their personal advisory accounts. We calculate our standard Fees on a retroactive basis instead of on an incremental basis. As the aggregated Relationship Value (described in further detail on the following page) reaches each higher asset tier, or “breakpoint,” the applicable Fee is reduced and assessed retroactively to the first dollar of your account assets. That is, our advisory programs have built in breakpoints to reduce fees as the assets in your advisory account(s) rise. Combining related accounts effectively acts as a discount to the standard program fee schedule by allowing you to achieve a lower breakpoint rate as your Relationship Value increases. For certain clients with substantial assets being considered for or currently participating in an advisory program, the Firm and your financial advisor may further discount its Fees to accommodate those clients. This generally occurs at the $10 million level for AMS managed program accounts, however, discounts for accounts that do not meet these minimum thresholds remain negotiable, but the Firm will not discount its breakpoint rates and as a result, your financial advisor may or may not be willing to negotiate his or her Fee. Aggregating related fee-based accounts to obtain additional fee discounts related to available breakpoints is further described below in the “Aggregation of Related Fee-Based Accounts” section. Fee Billing Practices When we calculate your Fee, we use “Account Value,” which may be different than the values as reported on your account statements. In your advisory agreement(s), which may include the Master Advisory Agreement, Account Value is defined as (i) the total of the absolute market values of each of the non-cash assets (e.g., securities, shares of funds, and other investment vehicles) in the account, long or short, in addition to the unrestricted cash, but (ii) excluding cash debit balances and non-billable assets (such as restricted cash for certain short positions). Please refer to the “Understanding your Account Statement: Account Statement Value and Account Value Differences for Fee-Based Accounts” section for information on the account valuation methodology we use to calculate the Fee. The advisory Fee for our Programs and Dual Contract Platform is typically payable quarterly in advance Your initial advisory Fee will be based on your initial contribution and will generally be assessed for the remainder of the current billing period; the initial Fee payment will become due in full on the date of account inception. Thereafter, the advisory Fee will be paid in advance and will be calculated on the Account Value, excluding any non-billable assets in the account, as of the last business day of the previous calendar quarter and will become due on the following business day. We may make accommodations to our billing procedures based on your specific request, from time to time under limited circumstances, subject to our sole discretion. Special Billing Procedure for Deposits or Withdrawals of $100,000 or More: If cash or securities, or a combination of cash and securities, amounting to at least $100,000 are deposited to or withdrawn from your account on an individual business day in the first two months of the quarter: (i) We will assess the Fee based on the Account Value on the date of deposit for the pro rata number of days remaining in the quarter, or (ii) We will refund the prepaid Fee based on the Account Value on the date of withdrawal for the pro rata number of days remaining in the quarter. (iii) We will not assess Fees, or make adjustments to, previously assessed Fees made in connection with deposits or withdrawals made during the last month of the quarter. In spite of the above $100,000 adjustment threshold, we reserve the right, to process or not process Fee adjustments when the source and destination of deposits and withdrawals involve your other AMS Managed and/or IAR Managed Program accounts. For example, a transfer of $100,000 into a joint RJCS account funded from two $50,000 withdrawals from separate Ambassador accounts would have the $100,000 billed in their joint RJCS Program account and each of the Ambassador accounts will be refunded previously assessed Fees on the separate $50,000 withdrawals for the pro rata period remaining in the quarter. Unless you elect to receive a separate billing invoice, you authorize and direct us, when acting as custodian, or sub-custodian, to deduct Fees from one of your accounts. Your account statements show all amounts disbursed from your account, including the amount of the Fee and the Account Value on which the Fee was based. Details of the manner in which the Fee was calculated is available in the “Understanding your Statement” section which accompanies your quarterly statement". While we have designed reasonable controls to monitor for the accuracy of advisory Fees, it is your responsibility to verify accuracy of your Fees, including the advisory fee rate applied to your account(s). Understanding Your Account Statement: Account Statement Value and Account Value Differences for Fee-Based Accounts When acting as custodian, or sub-custodian, to your account assets, you will

be provided a quarterly (at least) account statement detailing the assets in your account(s) and activity in that period. There is a section in each statement entitled, “Understanding Your Statement” that provides you with information to help you understand the various sections and details of the statement. The Account Value is a specific calculation we use to calculate your Fee that takes into account a number of billing rules. For additional billing rules, please also refer to the Aggregation of Related Fee-Based Account and Special Billing Procedure for Deposits or Withdrawals of $100,000 or More sections. Account Value is not necessarily the same as other values reported on the account statements we send you. Here are some of the reasons why account statement values may differ from Account Value: 1. Trade Date versus Settlement Date – We include or exclude some securities in Account Value and charge the Fee on them although they are not shown on your account statement because the security settled after the end of the statement period, which is the last business day of the previous calendar quarter. Your account statement includes all securities and cash balances settled as of the end of the statement period. But when we calculate your Fee we treat cash balances and securities as being held in your account as of that security’s trade date and we value that security as of the end of the quarter, even though the security has not settled in your account yet. As a result, if you buy a security in your account and the purchase has not yet settled at quarter end, your account statement will show the cash we used to buy the security and not the security itself, but we will treat the security as if it is in your account and charge the Fee on it. 2. Treatment of Short Sale Transactions (Short Equities and Options) and Associated Cash Balances - Because your account statement reads like a balance sheet, securities held short (that is, you sold a security that you do not own) at the end of the billing period are shown as liabilities. However, we charge the Fee on the absolute value of short positions, meaning that while they are shown as a negative number (liability) on your account statement, we treat them as if you own them and we charge the Fee based on their market value, which is a positive number. For example, if you sold $20,000 of a security that you do not own, you hold a short position that reflects a $20,000 liability on your account statement. But, we treat your short position as an asset under management in your advisory account and we charge the Fee on that $20,000 short position. In this same example, we do not charge the Fee on the cash balances associated with the equity short sale and any ongoing cash requirements, because we reserve that cash to buy the shares to deliver to the buyer, or “close out” the short sale. This is referred to as restricted cash and will fluctuate based on the movement of the underlying short position. In contrast, we do charge the Fee on cash balances generated from short option positions, as we can use that cash to buy securities for your account. Here is an example of how we charge the Fee on short equity positions in your account: Let’s assume your account has a short equity position with a short market value of $20,000, long securities (securities you own) with a long market value of $85,000, and $20,000 in cash balances. Your account statement will show your account value to be $85,000. But we charge your Fee on the absolute market value of the positions in the account (Account Value), which is actually $105,000. The breakdown would be as follows: Here is an example of how we charge the Fee on short options positions in your account: Let’s assume you sell short an options contract equivalent to $20,000 (that is, you sell an options contract that you do not own). Let’s also assume that you hold this short option position instead of the short equity position in the example above. We will charge the Fee on the Account Value, which would be $125,000. The breakdown would be as follows: Amount Position Account Value ($20,000) Short position as shown on account statement Included as $20,000 for billing (absolute value) $85,000 Long equity position Included as $85,000 for billing $20,000 Cash position associated with the short position This cash is restricted and excluded from billing. $105,000 Absolute market value If any short position increases in value, you will have to pay more to buy the position you need to deliver to the buyer (close out the short position). If the share price is higher than your short sale price, you will have unrealized losses. This also means that the Account Value we use to calculate your Fee will increase as well and you will pay a higher Fee than if the short positions had not increased in value. The amount of your higher fee will depend on how much unrestricted cash you have in your account to offset the restricted cash we must hold for the short position. Any unrealized losses on short sales that result in a higher Fee to you will also increase the compensation to your Financial Advisor if the short position is held on the last business day of the previous calendar quarter and therefore included in your quarterly advisory Fee. If you own large short positions or maintain a margin balance that is large compared to your other holdings, this generally results in the largest difference between the value shown on your account statement and the Account Value we use to calculate your Fee. The value on your account statement is reduced by liabilities (your short positions), while your Account Value and your Fee is increased by your short positions. If you hold large short positions or maintain a large margin balance relative to your other holdings, this difference likely will be significant, and your Account Value could be twice as large – or more – than value shown on your account statement. If you have questions on how margin or short values affect your fees under various circumstances, you should contact your financial advisor. 3. Cash Balances – Ambassador clients that hold cash balances greater than 20% of their overall Account Value as of the last business day of the quarter (“the valuation date”) for 3 consecutive quarterly valuation dates will have the cash balance above 20% excluded from the Account Value used to calculate advisory Fees. Please refer to the “Billing on Cash Balances Held in Ambassador Accounts” section for additional information. In the AMS Managed Program and OSM Platform accounts, cash balances are generally expected to be a small percentage of the overall account value and are included for billing purposes. Also, in the AMS Managed Program and OSM Platform accounts, cash balances as part of a dollar cost average or periodic investment plans are typically excluded from the Account Value used to calculate advisory fees. For example, a client that has instructed us to invest $25,000 in monthly increments over the course of the next six months will have this cash balance reflected on his or her account statement, but this balance is excluded from the Account Value until invested, and therefore not assessed an advisory fee. However, in Ambassador accounts, monies set aside for dollar cost average or periodic investments plans are included in the Account Value. For more information concerning periodic investment plans, please refer to the “Opening an Account: Account Funding and Documentation Requirements” section. 4. Non-Billable Assets – Clients that hold securities and other assets designated as “non-billable” are not assessed advisory fees on these positions. As a result, the Account Value upon which the advisory fee rate is applied will not include the value of these positions, although these positions will be included on the account statement. Please note that these non-billable assets may not be designated as such on your account statement. Please refer to the “Non-Billable Assets” section for additional information. 5. Primary Market Distributions - Clients that purchase initial public offerings and other new issues where brokerage commissions are included in the offering and we are a distribution participant are not assessed advisory fees on these positions for one year from their purchase date. As a result, the Account Value will not include the value of these positions, although they are reflected on the account statement. Please refer to the “Participation or Interest in Client Transactions” section for additional information. 6. For purposes of calculating Account Value, the market value of any fee-based annuity linked to your Ambassador account is based on the market value of the annuity as disclosed on your RJ brokerage statement. Your account statement value may differ from the Account Value for reasons other than those listed above. Positions subject to the 20% cash balances policy, non-billable assets, or other excluded positions in the account will result in differences between the Account Value and account statement value. The methodology we use to derive the Account Value is intended to include assets or positions in your advisory account that we consider to be “assets under management”. Account Valuation and Pricing We rely on third party pricing services to determine the value of your account assets. These values are shown on your account statements and are used in preparing your performance reports. However, if you have assets custodied with a third-party custodian and if the third party pricing service does not provide a price for assets in your account, we generally rely upon the price reported by your third party custodian. The prices shown on your account statements provided by the third-party custodian could be different from the prices shown on statements and reports provided by us. While sources used for pricing publicly traded securities and other investments are considered by us to be reliable, the prices may be based on actual trades, bid/ask information, vendor evaluations, or other methodologies. As a result, these prices may or may not reflect the actual trade prices you would receive in the current market. Pricing for non-publicly traded securities and other investments are obtained from a variety of Amount Position Account Value ($20,000) Short option position as shown on account statement Included as $20,000 for billing (absolute value) $85,000 Long equity position Included as $85,000 for billing $20,000 Cash position generated by the short option position Included as $20,000 for billing, (this cash is unrestricted and can be used to buy additional securities) $125,000 Absolute Market Value sources, which may include issuer-provided information (such as for limited partnerships, real estate investment trusts, annuity firms and other alternative investments). We cannot guarantee the accuracy, reliability, completeness, or availability of this information. Aggregation of Related Fee Based Accounts We aggregate fee-based accounts for billing purposes based primarily on information provided by financial advisors and clients. It is your obligation to notify your financial advisor if there are accounts that you believe should be included as “related.” Upon your request, we will aggregate your related fee-based accounts for billing purposes so that each account pays a Fee under the disclosed program fee schedule that is calculated on the basis of the total combined Account Value of all related accounts (“Relationship Value”), although, we reserve the right to determine whether accounts are “related.” In general, related accounts are typically combined based on how you instruct your financial advisor to link your accounts for the delivery of account statements, trade confirmations, and other forms of client communications (for example, the combination of accounts contained in an account statement delivery packet delivered to a unique address). However, your financial advisor may consider additional accounts even when account statements are being delivered to multiple addresses. Combining related accounts effectively acts as a discount to the standard program fee schedule by allowing you to achieve a lower breakpoint rate as your Relationship Value increases. As a result, it is important for you to consult with your financial advisor, as factors other than the social security number or tax identification number may be considered by the financial advisor when combining accounts for fee billing purposes. For example, accounts of a spouse or domestic partner, your children, or other relatives may be combined based on your collective relationship with your financial advisor. Please note that we may be limited in our ability to combine your retirement accounts where a prohibited transaction under the Employee Retirement Income Security Act of 1974 (“ERISA”) or the Internal Revenue Code of 1986, as amended, may result. The negotiated discount rate applies until the disclosed program fee schedule breakpoint results in a lower Fee. Financial advisors receive more compensation if the aggregation of related fee-based accounts is not applied. It is important for you to disclose to your financial advisor for consideration any and all potential and applicable relationships that have the potential to result in your account(s) receiving a breakpoint discount. Standard Fee Schedules for AMS Managed and IAR Managed Programs and Dual Contract Platform Below are the fee schedules for the available Programs and Dual Contract Platform previously discussed. Advisory Programs Up to $1M $1M-$2M $2M-$5M $5M-$10M $10M + RJCS Equity/Balanced – Schedule A Equity/Balanced – Schedule B 2.75% 2.60% 2.50% 2.35% 2.25% 2.10% 2.00% 1.85% 1.75% 1.60% Fixed Income – Schedule C 2.55% 2.30% 2.05% 1.80% 1.55% Laddered Bonds & Short-Term Conservative Fixed Income – Schedule D 2.45% 2.20% 1.95% 1.70% 1.45% MDA 2.60% 2.35% 2.10% 1.85% 1.60% RJRP 2.60% 2.35% 2.10% 1.85% 1.60% Freedom UMA Standard strategies 2.60% 2.35% 2.10% 1.85% 1.60% Traditional and Strategic strategies 2.50% 2.25% 2.00% 1.75% 1.50% Freedom 2.25% 2.00% 1.75% 1.50% 1.25% Portfolio Select UMA 2.60% 2.35% 2.10% 1.85% 1.60% American Funds 2.25% 2.00% 1.75% 1.50% 1.25% Russell 2.25% 2.00% 1.75% 1.50% 1.25% BlackRock 2.25% 2.00% 1.75% 1.50% 1.25% Ambassador 2.25% 2.00% 1.75% 1.50% 1.25% OSM1 2.25% 2.00% 1.75% 1.50% 1.25% 1The fee shown reflects only RJA's Platform fee. A separate OSM Manager fee also applies. Manager Fees in the RJCS, Freedom UMA, MDA and Portfolio Select UMA Programs We negotiate the management fee payable to the Managers in each of these Programs, based on factors including, but not limited to, the Manager’s assets under management in the RJCS and (if applicable) Freedom UMA, MDA and Portfolio Select UMA Program(s), the Manager’s participation as a Model or Discretionary Manager, Manager’s participation in multiple programs, anticipated sales, and administrative service levels, among others. As with any negotiation, Managers may agree to or counter our proposed payment rate, or otherwise decline to participate in any of our Programs if they so choose. A Manager’s decision to participate in the RJCS, MDA, Freedom UMA and/or Portfolio Select UMA Program is theirs alone to make (upon Firm approval to include them in our Program) and may be based on economic considerations. The range of the Managers’ fees for these programs are disclosed below but may vary due to the incremental rates negotiated between our Firm and the applicable Manager. These Manager fees are part of the wrap fee you pay. Advisory Program Model and Discretionary Manager Fees RJCS through Model Managers or SMA Managers 0.18%-0.50%: Equity and Balanced 0.12%-0.32%: Fixed Income MDA 0.30% Freedom UMA and Portfolio Select UMA (through Model Managers) 0.20-0.35% The negotiated management fee may differ between Managers and the Manager fee paid by us to the Manager may be more or less than the Manager may receive for providing similar services pursuant to another sponsor’s SMA, MDA, UMA and/or Portfolio Select UMA Program(s). Although the basis of our recommendation of Managers is not contingent upon this negotiated management fee, a conflict may exist due to the potential incentive we may have to recommend Manager(s) with a lower management fee. The lower the negotiated management fee, the more revenue the Firm retains. For example, if you select the RJCS Program and are paying the 2.75% advisory fee for an Equity/Balanced strategy, you may have more than one Manager to choose from. If the Manager Fee for Manager X is 0.45% and the Manager Fee for Manager Y is 0.40%, we would retain the 0.05% difference between Manager X and Manager Y’s fee; however, your financial advisor would not share in this additional revenue because he/she is allocated the same percentage of the standard fee schedule regardless of Manager or Program. However, if you and your financial advisor have agreed to a Fee other than the standard fee listed in the Standard Fee Schedules above and you are using a Schedule A and Schedule B Manager within the RJCS Program, your financial advisor will earn additional revenue from the use of a Schedule B Manager provided the same negotiated fee is being applied to both the Schedule A and B Managers. As described below, we monitor the appropriateness of advisory accounts to mitigate such potential conflicts. Please consult with your financial advisor concerning the RJCS Managers and their Manager fees if you have additional questions. Similarly, the Firm retains more compensation (i.e., we can earn more) when a Model Manager(s)(rather than an SMA Manager) is selected by you in our programs because in Model Manager disciplines or strategies, AMS is providing the discretionary management services as described under the RJCS Program page. Generally, the Model Managers are paid a lower management fee (i.e., allocated less of the Fee paid by you) than SMA Managers where the SMA Manager provides discretionary management. Because we retain more of the Fee when a Model Manager is selected and AMS provides the discretionary management, there is a conflict of interest when recommending Model Managers’ disciplines or strategies over SMA Managers’ disciplines or strategies. However, our financial advisors only know the range (displayed above) that an individual Manager is paid and do not know the exact percentage that Manager has negotiated with the Firm. Please refer to the “Financial Advisor Compensation” section for more information. Additionally, we may seek to diversify our Freedom UMA account portfolios with mutual funds in cases where investing in a Manager’s allocation would be impractical due to the allocation percentage or asset class, such as small cap, international, alternatives and fixed income. Conflicts of interest exist for us to allocate a higher proportion of our Freedom UMA portfolio to mutual funds where no management fee is paid by us to a Model Manager from your Fee. This would allow us to retain a higher proportion of the overall Fee. For more information about expenses you may incur outside of the selected wrap fee program, please refer to the “Additional Expenses” section. We have a fiduciary duty to act in your best interest and as a result, we supervise the activities of our financial advisors to ensure that the provision of investment advice to you is appropriate. In addition, we monitor the appropriateness of existing advisory accounts on an ongoing basis by conducting various reviews, such as identifying situations where a client’s risk tolerance is misaligned with the suitability risk, as assigned by the firm, of the selected account strategy. Non-Billable Assets Certain securities or other investments may be held in your Ambassador account and designated as non-billable assets. There are two primary categories of non-billable assets: Client-designated and Raymond James-designated (“RJ-designated”). Client-designated non-billable assets may be designated by financial advisors that do not wish to collect an advisory fee on certain assets, while RJ-designated non-billable assets are designated by us in accordance with Firm policy. For example, a financial advisor may make an arrangement with you to hold a security or investment that the financial advisor did not recommend. Or you may wish to hold a security or investment for an extended period of time and do not want your financial advisor to sell the security for the foreseeable future. In these cases, your financial advisor may elect to waive the Fee on this investment or security but allow it to be held in your advisory account. Assets designated by you as temporarily exempt from the advisory fee fall into the Client-designated category. Alternatively, we may determine that certain securities and other investments may be held in an advisory account but are temporarily not eligible for the Fee (mutual funds, market-linked notes and market-linked certificates of deposit, and unit investment trusts (“UITs”) purchased with a front-end sales charge through us within 12 to 24 months, dependent on the investment, and certain primary market offerings with embedded commissions). Certain mutual funds converted to advisory fee eligible share classes may become eligible if held at least one year, subject to certain conditions. Certain primary market offerings with embedded commissions become eligible for fee billing, if held for at least one year from the trade date where commissions were incurred. For additional information regarding exclusion periods, please refer to the “Conversion of Mutual Fund Share Classes and 12b-1 Fees” section. Assets designated by us as temporarily exempt from the advisory fee fall into the RJ-designated category. In this category, an advisory fee will not be assessed during the period the asset is not fee eligible. Alternative Investments that pay upfront and/or ongoing commissions or administrative/servicing fees are designated as non-billable assets for as long as the position is held in the advisory account. The following chart illustrates which Ambassador account types permit the use of Client-Designated and RJ-Designated non-billable assets: Account Type Client-Designated RJ-Designated Non-retirement Permitted Permitted Retirement Not Permitted Permitted Further, uninvested cash can be coded as a non-billable asset in both retirement and non-retirement Ambassador accounts. PLEASE NOTE: Client-designated non-billable assets, with the exception of cash, and the maintenance of these positions in your account are not permissible in Ambassador retirement accounts (such as individual retirement accounts (“IRAs”) and employer sponsored retirement plans). We have elected to preserve the ability for clients and their financial advisors to designate assets as Client-designated non-billable assets in their taxable Ambassador accounts as a customer service accommodation, in order to maintain client choice and avoid the need to maintain a separate account to hold these securities and other investments or cash. You should understand that not being assessed a Fee introduces a conflict that the financial advisor’s advice may be biased as a result of his or her not being compensated on this asset. Your financial advisor may recommend that you liquidate a non-billable asset in lieu of transferring the position to a brokerage account and use the proceeds to purchase an asset that is eligible for fee billing in your advisory account. While the advice must be appropriate for your advisory account, your financial advisor will generally receive more revenue from an asset that generates an ongoing revenue stream (compared to a brokerage account) or from an asset that is eligible for fee billing compared to one that is not. For questions about which assets are billable or non-billable, please consult with your financial advisor. Non-billable assets are not included in the Account Value when calculating the applicable advisory fee. For example, a client whose Ambassador account holds $750,000 of cash and securities/positions that includes $150,000 of non-billable assets will only have the Fee assessed based on the $600,000 Account Value. For clients with multiple fee-based accounts, the Relationship Value is used to determine the applicable fee rate that is assessed. However, you should understand that any assets held as non-billable assets are not included in the Relationship Value. Please see the “Aggregation of Related Fee-Based Accounts” section for additional information on how we combine related accounts for fee billing purposes. Cash Sweep Program The cash sweep program is a service that allows clients to earn interest on cash awaiting investment (“Cash Sweep Program”). We offer a deposit sweep called the Raymond James Bank Deposit Program (“RJBDP”), which includes certain variations described in greater detail below. In addition, we offer a cash feature called the Client Interest Program (“CIP”) in which eligible accounts earn interest on cash awaiting investment. We refer to both RJBDP (including the variations described below) and CIP as “sweep options” throughout this Brochure. The Cash Sweep Program is offered at no additional charge or cost to you. Please refer to the “Billing on Cash Balances Held in Ambassador Accounts” section described below for information on how Fees are applied to cash balances held in certain wrap fee programs over extended periods of time. In addition, please refer to the “Compensation Associated with Our Cash Sweep Program” section for information about the compensation we or our affiliates receive and/or share with other parties. Your financial advisor can provide you with additional information about Cash Sweep Program eligibility. Or you may refer to “Sweeps (Transfers) To and From Income-Producing Accounts” in the “Your Rights and Responsibilities as a Raymond James Client” brochure or the cash sweep section of the “Important Client Information” Brochure, a current copy of which is available at https://www.raymondjames.com/legal-disclosures or from your financial advisor, or you may visit our public website for additional information: https://www.raymondjames.com/wealth- management/advice-products-and-services/banking-and-lending-services/cash-management/cash-sweeps. Not all Cash Sweep Programs are available in all accounts, and some account types have only one sweep option available. Refer to the chart below for a description of the cash sweep options available by account type. In addition, not all Cash Sweep Program offers are available to all clients1. Available Sweep Options by Account Type 1 RJA, in its sole discretion, may amend the Cash Sweep Program to change the sweep options and/or interest rate tier (“Interest Rate Tier”) available, based on account type or other eligibility criteria, and in that case RJA may change the sweep option and/or Interest Rate Tier in one or more of your existing accounts. Please refer to the “Current Interest Rates for CIP and RJBDP” section below for information on Interest Rate Tiers and special offers. Every RJBDP bank, including every Excess Bank may decide in its sole discretion that it will cease to accept any funds (or any further funds) under RJBDP. In those cases, those funds you have will not sweep and instead will be held at RJA subject to SIPC and excess SIPC coverage within applicable limits. RJA may, if permissible by law and if in compliance with eligibility criteria for CIP as established by RJA, treat those unswept funds as part of CIP, subject to all terms and conditions applicable to CIP. For more information, please refer to the cash sweep section of the “Important Client Information” Brochure. A current copy is available at https://www.raymondjames.com/legal-disclosures or from your financial advisor, or you may visit our public website for additional information: https://www.raymondjames.com/wealth-management/advice-products-and-services/banking-and-lending-services/cash-management/cash- sweeps. Current Interest Rates for CIP and RJBDP Your interest rate is based on the total of the cash balance in RJBDP and CIP (collectively, “Relationship Cash Value”), as well as the Interest Rate Tier for which your accounts are eligible. For current Interest Rate Tiers for CIP and RJBDP, refer to https://www.raymondjames.com/wealth- management/why-a-raymond-james-advisor/client-resources/market-numbers/deposit-rates. For information on the rate being paid on your particular account(s), please contact your financial advisor or consult your periodic account statements. In addition, Raymond James, in its sole discretion, periodically offers special Interest Tier Rate offers (“Special Sweep Offers”) with specific terms and conditions, including limited eligibility criteria that materially differ from Relationship Cash Value. Please refer to our website www.raymondjames.com/rjbdp to view any current Special Sweep Offers or contact your financial advisor for additional information. The interest rate or yield on our Cash Sweep Programs may be higher or lower than the yield or interest rate available in other sweep programs at other institutions. You should consider the impact of cash and cash equivalents on your overall portfolio and whether you could receive more favorable rates of return by investing in other asset classes, including alternatives to cash such as money market mutual funds and treasury bills. Billing on Cash Balances Held in Ambassador Accounts If the cash sweep and foreign currency balances (“cash”) (not non-sweep money market funds) exceeds 20% of the Account Value as of the last business day of the quarter (“the valuation date”) for three (3) consecutive quarterly valuation dates, the amount in excess of 20% is excluded from billing (the “Cash Rule”). For example, an Ambassador account that held 30% of the Account Value for three (3) consecutive billing valuation dates (March 31st, June 30th, and September 30th) would have the amount in excess of 20% excluded from the Account Value upon which Fees Cash Sweep Option Description Non-retirement accounts (e.g. individual, joint, trust) ERISA/IRA advisory accounts IRA, non- advisory accounts RJBDP Uninvested cash in your custodial account through RJA are automatically deposited, or “swept,” into interest-bearing deposit accounts at participating banks. Two affiliates, RJ Bank and TriState Capital Bank, are participating banks in RJBDP. Yes No Yes RJBDP with RJ Bank Only Uninvested cash in your custodial account are swept into an interest-bearing deposit account with our affiliate, RJ Bank. Yes Yes Yes CIP CIP is a short-term alternative for cash awaiting investment. Cash in CIP is solely our obligation, whereas the funds on deposit through RJBDP and RJBDP-RJ Bank Only are obligations solely of the participating banks. A significant portion of CIP cash held for the exclusive benefit of clients is placed in overnight repurchase agreements that are fully collateralized by U.S. Treasury securities or deposited in qualifying trust or cash accounts with major U.S. banks. The remaining balance of CIP cash is used by us for our business operations, where permitted by law. Yes No No are applied. For simplicity of illustration, assuming an account was valued at $100,000 for all three (3) quarterly billing periods, with $30,000 held in cash, the September 30th valuation date would exclude $10,000 of the cash from the Account Value when assessing the Fee. The exclusion of excess cash from the Fee is intended to benefit clients holding substantial cash balances (as a percentage of the total individual Account Value) for an extended period of time. The portion of the account held in cash experiences negative performance when the applicable Fee charged is higher than the return received on the cash sweep balance. Within the Ambassador account, the Cash Rule applies on an individual account basis. The Cash Rule may pose a financial disincentive to a financial advisor as the portion of cash sweep balances in excess of 20% is excluded from the Fee charged to the account. This may cause a financial advisor to recommend a reallocation of your account from cash to advisory fee eligible investments, including money market funds, or to recommend against raising cash, to avoid the application of the Cash Rule and therefore receive a Fee on the full account value. You may direct your financial advisor to raise cash by selling investments or hold a predetermined percentage of your account in cash at any time. Additional Bundled Service Cost Considerations Your total cost for each of the services provided through our advisory programs, if purchased separately, could be more or less than the costs of each respective program. In addition, you may be able to obtain similar services for a lesser fee from other financial advisors within our Firm. The Fees charged vary among our advisory programs and our financial advisors. Cost factors may include your ability to:
• Obtain the services provided within the programs separately with respect to the selection of portfolio securities and other investments,
• Invest and rebalance the selected mutual funds without the payment of a commission or sales charge, and
• Obtain performance reporting comparable to that provided within each program. Some clients favor an asset-based fee arrangement because the fee sets their brokerage cost at a predetermined level. Other clients may favor a commission arrangement because they anticipate their accounts will have little trading activity. If you plan to follow a buy and hold strategy for the account or do not wish to receive ongoing investment advice or management services, you should consider opening a brokerage account rather than an advisory account. In a brokerage account, you are charged a commission for each transaction, and your registered representative has no duty to monitor your account or provide ongoing investment advice concerning the account or your investments. When assessing a wrap fee program’s cost, you should consider the amount of trading activity you anticipate, each of the wrap fee programs offered by us, and factors such as commission rates, your investment experience and knowledge, and your availability to monitor and rebalance investments. You should review and consider if you would pay more or less than when purchasing these services separately either through us or another service provider, depending on commission rates and portfolio trading activity. We make no guarantees that the aggregate cost of a particular program is lower than that which may be available elsewhere. You should explore this subject thoroughly with your financial advisor to determine whether an advisory (asset-based fee) or brokerage (transaction-based fee) arrangement is appropriate for your needs. Additional Expenses You may also incur charges for other account services, which we can provide at your election that are not directly related to the advisory, execution, and clearing services provided by us as part of the wrap fee program. Our advisory fee does not cover the expenses, charges, and costs listed below (not an all-inclusive list).
• Certain dealer mark-ups and odd lot differentials.
• Mark-ups, mark-downs, spreads, underwriting fees, selling concessions, or other transaction charges associated with a principal transaction effected by us or our affiliate with respect to a transaction.
• Taxes (including unrelated business taxable income in retirement accounts and financial transaction taxes).
• IRA custodial fees.
• Safekeeping fees.
• Debit interest charges: If you incur a cash debit or deficit in your account, you will pay interest on the negative balance in your account, even if your account is not a margin account. The rate varies depending on the size of the average debit balance and you will be responsible for the debit interest accrued in the account. Please refer to your account opening documents for additional information.
• Charges/interest for maintenance of margin and/or short positions (specific to certain Ambassador accounts, if selected and approved for margin). Refer to the “Buying Securities and other Investments on Margin and Margin Interest” and “Short Sales” sections for more information.
• Fees for legal or courtesy transfers of securities and other investments.
• Exchange fees and regulatory transaction fees charged to you to offset fees we pay to exchanges and/or regulatory agencies on certain transactions (for example, the Regulatory Transaction (RT) Fee is collected to recoup transaction fees paid by us to an exchange or self-regulatory organization in connection with the sale of certain securities and other investments).
• Offering concessions, and any other fees and expenses for purchases of public offerings of securities and certificates of deposit, as more fully disclosed in the prospectus and offering documents.
• Trade away commissions: When a third-party Manager elects to trade away and there are brokerage commissions or other charges associated with the transaction, your overall program costs increase. Please refer to the “SMA Managers that Elect to Trade Away from Raymond James” section for additional information regarding trades executed away from us.
• Fund and annuity operating costs and expenses and Fund distribution fees; for more information refer to the “Investment Costs” section below.
• Transfer fees.
• Return deposit items (check/ACH).
• Wire fees (outgoing).
• Fees and costs (such as conversion and foreign exchange fees, ongoing custody or service fees charged by American Depository Receipts (“ADR”) depository banks for inventorying the underlying non-U.S. shares and performing related administrative services) are associated with the purchase of non-U.S. securities in ordinary form and conversion of these ordinary shares into ADRs. ADRs are the receipts for the shares of a non-U.S.-based company traded in U.S. markets. These transactions typically are reflected in the net price paid or received by the client.
• Any other charges imposed by law or otherwise agreed to by you with regard to transactions in your account. For a list of account fees and service charges that may apply to your advisory account, please contact your financial advisor or visit our public website: raymondjames.com/services_and_charges.htm (Client Account Fees and Charges). Additionally, you may call us by phone at 800-647- SERV (7378) for additional information or may submit your written request to Raymond James Client Services, 880 Carillon Parkway, St. Petersburg, FL 33716. Investment Costs (relating to investments including Funds, annuities, alternative investments, market-linked investments, and unit investment trusts) If you invest in mutual funds and/or ETFs or annuities as part of your portfolio in any of the MDA, Freedom UMA, Freedom, Portfolio Select UMA, Ambassador, Russell Funds, and American Funds Programs or OSM Platform described in this Brochure, you also pay your pro-rata share of the annual management fees and operating expenses charged by open-end and closed-end mutual funds, ETFs and annuity companies. The cost structures of Funds differ significantly, typically ranging from 0.75% to 1.5% for mutual funds versus .20% to 1% for ETFs, and 0.07% to 2% for UCITS. These are the underlying fees related to investment products you purchase within your advisory account. These annual management fees and operating expenses are assessed by the fund or annuity sponsor directly and not by us, and, for clients who use an investment manager or investment strategy that invests in these investment products, generally results in clients paying more than clients using a manager or strategy that invests in individual securities, and other investments without taking into effect negotiated asset-based fee discounts, if any. The AMS Investment Committee, in the applicable AMS Managed Programs, considers the annual expense ratio when selecting funds; however, the AMS Investment Committee is not obligated to select a mutual fund or ETF with the lowest expense ratio and instead makes decisions based on other investment-related factors. In addition, you pay sales charges, redemption fees and other fees assessed by the Fund, annuity sponsor or alternative investment, if any. Some investments may have direct or indirect costs related to liquidating your position, particularly if an investment is liquidated shortly after being purchased or if an investment is specifically designed to provide limited or no liquidity to investors. Redemption fees assessed by an alternative investment manager can be as high as 5% of your investment. Certain mutual funds offered in these programs may impose short- term trading charges for redemptions (typically 1%-2% of the amount redeemed) made within short periods of time. These short-term charges are imposed by the fund companies (and not us) to deter “market timers” who trade actively in mutual fund shares. If you intend to hold fund shares for an extended period of time, it may be more economical for you to purchase fund shares outside of our advisory programs. You may be able to purchase investment products directly from the product sponsor without incurring our advisory fee. In this case, you would not receive the services provided by our Firm, which are designed, among other things, to assist you in determining which investment products are most appropriate to your financial condition and objectives. You should consider these short-term trading charges when selecting the program and/or mutual funds in which you invest. When purchasing directly from a Fund, annuity or alternative investment sponsor, you may incur a front- or back-end sales charge. Lastly, distribution fees charged by mutual fund companies (also known as trails or 12b-1 fees) pursuant to Rule 12b-1 under the Investment Company Act are included in the calculation of the mutual fund company’s annual operating expenses, which are disclosed in the fund prospectus. If received by us for positions held in advisory accounts, 12b-1 fees are credited bi-monthly to your account(s), as applicable. For additional information regarding 12b-1 fees, please see the “Certain Fund Arrangements and Fund-Related Compensation” and “Conversion of Mutual Fund Share Classes and 12b-1 Fees” sections. Investment costs apply whether the investment product is sponsored or managed by an affiliated or unaffiliated company. When you invest in investment products managed by us, we or an affiliate will receive compensation for managing those investments and for other services provided based on the amount you invest. Please refer to the “Affiliated Managers and Funds” section for more information. These investment costs are in addition to the Fee that you pay directly from your advisory account. They are paid indirectly by you, for example, as a shareholder in a mutual fund, through the product, and are not separately deducted from your advisory account. Investment costs instead reduce the value of your investment in the product and reduce the investment performance of your advisory account. For specific information on each mutual fund or ETF’s expenses, please refer to its prospectus. For additional information regarding Fund investing, see raymondjames.com/legal-disclosures/packaged-product-disclosures. For annuities, depending on the product, and as more fully described in the annuity contract, you may pay an early withdrawal fee if you cancel during the surrender charge period. Costs and fees vary between insurance products. Please refer to the annuity contract for a detailed description of charges you will incur. Market-Linked Investments, also commonly known as Structured Investments, are specialized bonds (Market-Linked Notes) or bank CDs (Market- Linked CDs). In advisory accounts, purchases of Market-Linked Investments are not charged any sales commissions; however, clients who purchase Market-Linked Investments will still pay offering costs associated with issuing, selling, structuring, and hedging the products. Such costs are paid to the issuer, included in the initial offering price, and disclosed in the offering documents. In advisory accounts, purchases in Unit Investment Trusts (“UITs”) are not charged any initial or deferred sales charge; however, clients who purchase UITs will still pay any creation and development fees and any operational expenses incurred by the trust. SMA Managers that Elect to Trade Away from Raymond James It is important to note that trades executed in advisory accounts by us acting in our capacity as a broker-dealer are generally effected with no commission. As a result, you generally receive a cost advantage when we effect trades in your AMS Managed account versus those trades that are effected by an unaffiliated broker-dealer that charges a commission. The wrap fee assessed by us covers the cost of brokerage commissions on transactions only when effected through our Firm. The SMA Managers are not in a position to negotiate asset-based fee rates with us on behalf of their wrap fee clients, or to monitor or evaluate fee rates being paid by their clients or the nature and quality of the services they obtain from us. If an SMA Manager elects to trade away from us, the executing broker or dealer frequently assess a commission or other charges to the transaction, and these costs will be in addition to the wrap fee assessed by us. As a result, the net purchase or sale price reflected on trade confirmations provided by us on those trades reflect brokerage commissions or dealer mark-ups or mark-downs charged by the executing broker that are not separately itemized by us. Additionally, investment disciplines of SMA Managers that elect to trade away from us will generally be more costly to clients than those disciplines of SMA Managers that elect to trade exclusively or primarily through us. Some SMA Managers in the RJCS Program have historically directed most, if not all, of their program trades to outside broker-dealers, and only maintenance trades (i.e., trades resulting from individual new account openings, capital additions/disbursements, or account terminations) are effected through us. In the selection of brokers or dealers to effect transactions, the SMA Manager should consider all relevant factors, including, among other things, the value of research services, execution capability, execution speed, execution efficiency, confidentiality, familiarity with potential purchasers or sellers, commission rates, financial responsibility, responsiveness, or any other relevant matters. The SMA Manager can select brokers or dealers that provide the SMA Manager research or other transaction-related services. The provision of these services may cause the client to pay the brokers or dealers commissions or other transaction-related fees in excess of those that other brokers or dealers charge, including us. Research and other services may be used for other of the SMA Manager’s clients if permitted by law. SMA Managers that specialize in fixed income, international, small-cap or exchange-traded product disciplines will be more likely to trade away from us due to market dynamics, liquidity, exchange availability, institution specialty, or other factors they consider relevant in satisfying their best execution obligations to clients. As we are not a party to the transaction, our Firm is not in a position to negotiate the price or transaction related charge(s) with the executing broker. We do not discourage or restrict an SMA Manager’s ability to trade away, as the responsibility to determine the appropriateness of trading away from us falls under the SMA Manager’s individual fiduciary duty to clients and expertise in trading their portfolio securities and other investments. As the potential exists that clients can be assessed additional costs when selecting an SMA Manager that elects to trade away from us, these SMA Managers’ equity and balanced disciplines have been identified in the Investment Discipline Selection section of the advisory agreement(s) which could include the Master Advisory Agreement for clients to consider during their selection process. Additional information describing the trading practices of SMA Managers participating in the RJCS Program, identifying those SMA Managers that frequently traded away equity orders from us and the average additional costs associated with these trades, is available on our public website. Please refer to the “Important Information Regarding Investment Manager Trading Practices” section at www.raymondjames.com/disclosure-trading-practices or you may request a copy from your financial advisor. While it is important for you to have access to this information to aid in your decision-making process, we believe it equally important that you review the historical performance of these SMA Managers, which reflects these additional costs (that is, such performance presentations reflect the “net” price at which all transactions were effected, including those that were traded away where an additional commission, markup, or markdown was assessed by the executing broker or dealer). The “market” for fixed income securities and other investments is largely comprised of dealers that trade over the counter amongst themselves, and very few securities and other investments trade on organized exchanges. Due to the structure of the fixed income market, the participating dealers do not currently, nor are they required to, disclose the mark-up, mark-down, or spread at which purchases and sales are effected. As a result, SMA Managers that trade fixed income securities and other investments away from us are unable to provide this information to us. In turn, we are currently unable to present this information to you. Compensation Firm Compensation We provide a wide variety of financial services to individuals, municipalities, corporations, and other business entities. We have business relationships with companies whose investment products and investment advisory programs we make available to our financial advisors and their clients. As a result of our recommendation to you, and your participation in one of our Programs, the Firm receives compensation, outside of your Fee, from other parties, as described below. This section describes the ways in which the Firm may be compensated (and therefore conflicted) by other parties outside of your Fee and how we mitigate those conflicts. The RJA Wrap Fee Program Brochure is designed to provide users of RJA-sponsored wrap fee programs with information related to each program and various ways RJA may receive additional compensation outside of the wrap fee. For clients of firms affiliated with RJA or who use RJA-sponsored programs, please refer to your firm’s Form ADV Part 2A or equivalent brochure for important information about how your individual financial advisor is compensated, any related conflicts and other important disclosures such as your firm’s disciplinary history. The presence of compensation creates an incentive for us to recommend that you invest in Funds (or other investments) and share classes that pay higher fees to us or our affiliates. It is possible that these compensation arrangements also cause us and our affiliates to forego opportunities to negotiate more favorable financial terms for client investments in Funds or to recapture all or a portion of the amount of these fund-related compensation for your benefit. We or our affiliates may effect transactions for a Fund offered through one of our advisory programs, and any compensation paid to us or our affiliates by the fund manager or any of their affiliates is additional compensation to us for services we and our affiliates provide to them. Our Firm, in managing advisory accounts, has a financial incentive to favor investments that pay us education and marketing support fees (“E&M support fees”), networking and/or omnibus and other administrative and/or service-related fees further described above over investments that do not. We also have an incentive to select those investments that pay higher amounts of compensation to us for E&M support fees, networking and/or omnibus and other administrative and service-related fees over those investments that pay lower amounts of compensation to the Firm. We also receive non-E&M support fees which are further described in the “Other Compensation” section below. We address the conflicts of interests associated with the payment of compensation in the following ways. In this section, we disclose compensation we receive from product sponsors and other service providers. We have adopted various policies and procedures reasonably designed to prevent the receipt of compensation from third-parties from affecting the nature of the advice we and our financial advisors provide as described throughout this Brochure. In regard to the Freedom and Freedom UMA Programs managed by us, the AMS Investment Committee makes investment decisions based on objective, investment related due diligence and are agnostic to the compensation arrangements with the various investment companies. Additionally, we and our affiliates select investments that are available on our investment advisory platform and offered through our advisory Program based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and consistency of the execution of their strategy. Receipt of Sponsorship Fee Compensation from Product Sponsors or Service Providers From time to time, we receive additional compensation from product sponsors and service providers in the form of sponsorship fees for seminars, meetings, or conferences. Our receipt of these sponsorship fees is for the purpose of defraying costs associated with coordinating and hosting the sponsored event. These sponsorship fees generally entitle the sponsor an opportunity to conduct a presentation of the sponsor’s products or services, among other things, to representatives of our Firm and our affiliates. Due to the large number of product sponsors and service providers whose products and services are offered by us, it is important to understand that not all product sponsors and service providers can participate in a given meeting or event or will be available or choose to participate in any event for an extended period of time. As a result, only those product sponsors and service providers that participate in these events gain the opportunity to interact with our representatives, and it is anticipated that these interactions will result in additional sales of those products or services. Accordingly, a conflict of interest may exist where we offer presentation opportunities to those product sponsors and service providers willing to contribute sponsorship fees more frequently or in greater amounts than other product sponsors and service providers. Consideration of product sponsors and service providers for participation in one of our events is also based on the quality of the product sponsor or service provider and is not solely based on the anticipated sponsorship fees our Firm will receive. Clients or potential investors that attend a training or educational meeting offered by their financial advisor where a product sponsor or service provider is in attendance should assume that the product sponsor or service provider has paid or reimbursed us or our affiliates for part or all of the total cost of the meeting or event, including travel costs. Education & Marketing (“E&M”) Program Fees Through the E&M Program, we, or our affiliates, receive compensation from certain product sponsors who offer securities and other investments/products, to both affiliated and unaffiliated investment advisers. These payments are intended to compensate us and/or our affiliates for a variety of education, training, marketing, and other sales support and services. In particular, our Firm and/or our affiliates receive a minimum E&M support fee up to $250,000 from our product sponsors (for e.g., mutual fund, ETF, and annuity companies) to participate in the E&M program. Our Firm and/or our affiliates also receive annual fees of up to $25,000 for providing education, training, marketing, and sales support services for our financial advisors that provide or seek to provide services to employer-sponsored programs. The structure of payments to participate in the E&M program generally varies among product sponsors – a percentage of assets under management, a flat dollar fee, or some combination thereof. However, the potential level of marketing support fees (also known as revenue sharing fees) that we receive from a particular product sponsor will generally not exceed 0.30% per year on assets held through us, subject to any applicable minimums. These payments are generally not disclosed in detail in a particular product’s prospectus or statement of additional information (“SAI”). The actual amounts that we and/or our affiliates receive vary from one product sponsor to another depending on the level of support and types of services provided by our Firm. We do not collect E&M support fees on ERISA plan assets and certain fee-based retirement accounts. More information about the E&M marketing support fees paid to us and/or our affiliates by our product sponsors, including but not limited to mutual fund, ETF, annuity, insurance, market-linked investment, and trust sponsors, as well as a list of those companies that have agreed to participate in our E&M program is available on our public website: https://www.raymondjames.com/legal-disclosures/packaged-product-disclosures. You may also receive a hardcopy of this list by contacting your financial advisor, or by contacting AMS at (800) 248-8863, extension 74991, or by sending in a written request to: AMS, Client Services Department, 740 Carillon Parkway, St. Petersburg, FL 33716. Compensation Associated with Offering Certain Services to Related Funds We make available a variety of mutual funds advised or offered by our affiliate, Carillon Tower Advisers, Inc. (“CTA”), doing business as Raymond James Investment Management which includes all mutual funds under the Raymond James Investment Management umbrella. In addition to the fees described in the “Service, Fees, and Compensation” and “Intercompany Payments Between Affiliates” sections, we receive additional revenue in connection with the sale of Raymond James Investment Management mutual funds for providing these affiliated mutual funds with investment advisory, administrative, transfer agency, distribution, and/or other services that we may not provide to unaffiliated mutual funds. Payments to our Firm and our affiliates made by mutual funds advised or offered by Raymond James Investment Management may be terminated, modified, or suspended at any time. We benefit from increased sales of related funds and other investment products of related funds and managers as compared to increased sales of funds and other investment products of other unaffiliated firms. We address these conflicts by disclosing them in this brochure and monitoring the provision of advice by our financial advisors to ensure that the provision of advice is appropriate based on your stated investment objectives and risk tolerance. Our financial advisors and branch managers do not receive additional compensation or other cash or non-cash incentives for recommending mutual funds (or any particular class thereof) advised by Raymond James Investment Management. Compensation Associated with FT-ETF Sub-Advisory Services As the sub-advisor to the FT-ETF, ticker symbol RJMG, RJA will annually earn 30 basis points of the total annual management fee collected by First Trust. The sub-advisor fee earned by RJA for its model portfolio services to the FT-ETF is separate from, and in addition to, the Fee charged by RJA and your financial advisor for services provided in advisory accounts eligible to hold the FT-ETF. For example, if a FT-ETF was purchased in your Ambassador account, you would be subject to the agreed-upon advisory fee for your financial advisor’s ongoing advice and services within the Ambassador account and separately for any internal expenses related to the FT-ETF as described in the fund’s prospectus which, includes compensation paid to RJA for providing the model portfolio to First Trust. As a result, our Firm will earn additional revenue when a FT-ETF is purchased within an Ambassador account as opposed to a non-affiliated ETF. Please see the “ETF Sub-Advisory Services” section in this brochure for more information about the FT-ETF and related conflicts of interest. Certain Fund Arrangements and Fund-Related Compensation Only shares of those mutual fund companies with which our Firm has a selling agreement are available for purchase from us. Further, the mutual funds available for purchase generally include those fund companies that provide us with compensation, including but not limited to E&M support (described above), Networking, and/or Omnibus fees (including Sub-Accounting, Sub-Transfer Agency, and Administrative Fees)(described below), and a few fund companies that do not pay such compensation but that we choose to offer to clients on our platforms (see link below under Networking and Omnibus Fees for a list of those mutual fund companies). Not all mutual funds available to the investing public are available for investment with us, and you should not assume that share classes with the lowest expense ratio are available. Eligibility for various share classes offered by mutual funds to be used as part of our advisory programs, as described under the “Overview of Our Advisory Programs” section, is determined by the mutual fund and disclosed in the fund’s prospectus. With respect to those funds that pay us compensation, we evaluate each share class for which the relevant advisory program is eligible and aim to select the lowest cost available share class that includes a fee which compensates us for sub-accounting, recordkeeping, and related services (also known as “Sub-TA Fees”) at the individual account level. This means that we may not select the lowest cost share class for which the program is eligible (because there may be a less costly share class that does not charge Sub-TA Fees). Moreover, while we seek to avoid using share classes that charge 12b-1 fees as part of our advisory programs, if the share class is the only means by which we can collect Sub-TA Fees from the fund (or if a non-12b-1 paying share class is not available to us due to contractual reasons or otherwise), we will use that share class and credit the 12b-1 fee to your account(s). Rule 12b-1 fees are credited to client accounts bi-monthly, as applicable. Use of a more costly share class reduces the performance of your account. Your financial advisor does not have an incentive to recommend or select share classes that have higher expense ratios because his or her compensation is not affected by the share class selected. We also select a 12b-1 share class instead of a non 12b-1 share class if necessary to be eligible to collect E&M support payments from mutual fund advisers and affiliates. E&M support payments are not paid out of fund assets and do not affect your investment performance. These 12b- 1 fees, too, are rebated to client accounts. For additional information regarding 12b-1 fees, please see the “Conversion of Mutual Fund Share Classes and 12b-1 Fees” section. When evaluating the reasonability of the Firm’s compensation, you should factor in all types of compensation received by us for the sale of mutual fund shares in which you invest. Similar to mutual funds, not all money market funds available to the investing public are available for investment through us, and we only make available money market funds that provide us with compensation for sub-accounting, recordkeeping, or related services at the individual account level. Certain money market funds may be approved as an investment option but are designated as non-billable assets as long as these funds are held in a fee-based account (during the time period that the positions are not fee eligible). Neither we nor your financial advisor receive fee-based compensation on these funds but may receive compensation in the form of a 12(b)-1 fee, above-referenced service fees, or trail from the fund company, which are rebated to client accounts. Shareholders considering transferring mutual fund shares to or from us should be aware that if the firm from or to which the shares are to be transferred does not have a selling agreement with the fund company, the shareholder must either redeem the shares (paying any applicable contingent deferred sales charge (“CDSC”) and potentially incurring a tax liability) or continue to maintain an investment account at the firm where the fund shares are currently being held. You should inquire as to the transferability, or “portability,” of mutual fund shares prior to initiating such a transfer. If an account is transferred in with mutual funds (and it is subject to redemption fees assessed by the product sponsor), it could be liquidated by AMS and re-invested into the selected program. In AMS Managed programs, the discretionary manager may require a share class other than what was used to fund the account. When necessary, under the authority provided to us under your advisory agreement(s) which may include the Master Advisory Agreement, we may effect an exchange to another class of shares of the same investment company fund. In certain other programs including Ambassador and PSUMA, you may choose to select a mutual fund that is assessed a short-term redemption fee. For additional information on fees and mutual fund operating costs, short term trading redemption fees, etc., please refer to the Investment Costs section. Specific to the Freedom and Freedom UMA Programs, the AMS Investment Committee invests in funds or share classes designated by us for use in these AMS Managed Programs. In some instances, a fund company may agree to allow the AMS Investment Committee to buy an institutional share class of a fund for the Freedom Program accounts, while restricting individual client-directed purchases of the same share class in Ambassador. In addition, some shareholders may qualify to invest in share classes that are intended for specific types of investors, such as retirement plans, by prospectus. Networking and Omnibus Fees (Sub-Accounting, Sub-Transfer Agency, and Administrative Fees) We receive compensation from certain mutual fund companies for administrative, accounting, recordkeeping, sub-transfer agency or other services we and/or our affiliates provide. These payments for networking and omnibus services generally take the form of per account charges, a percentage of assets under management or flat dollar payments. The total amount of these payments may be up to 0. 25% of total assets under management. We do not receive fees on ERISA plan assets and certain fee-based retirement accounts. For additional information, please visit: https://www.raymondjames.com/legal-disclosures/packaged-product-disclosures. For a list of fund companies that:
• Have agreed to pay us networking and omnibus servicing fees, please visit: https://www.raymondjames.com/legal-disclosures/packaged- product-disclosures/mutual-fund-investing-at-raymond-james/networking-and-service-partners.
• Do not pay us networking and omnibus servicing fees, please visit: https://www.raymondjames.com/legal-disclosures/packaged-product- disclosures/mutual-fund-investing-at-raymond-james/non-networking-and-service-partners. You may also receive a hardcopy of this list by contacting your financial advisor, by contacting AMS by phone at (800) 248-8863, extension 74991 or by sending in your written request to: AMS, Client Services Department, 740 Carillon Parkway, St. Petersburg, FL 33716. Shareholder Servicing Fees Certain mutual fund companies also pay us fees to provide shareholder liaison services to investors. These fees are classified as shareholder servicing fees and generally include responding to investor inquiries and providing information on mutual fund investments. We receive these shareholder services fees from certain mutual funds in amounts up to 0.25% annually of the assets invested in a particular mutual fund. Conversion of Mutual Fund Share Classes and 12b-1 Fees An investment company may authorize us to make available to clients participating in one of our advisory programs a class of shares of a fund with a lower fee structure that we believe is more beneficial to you than the class of shares previously made available in the advisory program. Where an exchange is available, under the authority provided to us under your advisory agreement(s) which may include the Master Advisory Agreement, we may effect an exchange to another class of shares of the same investment company fund with the lower fee structure, as promptly as practicable and taking into account the administrative and operational requirements necessary to implement the exchanges. We periodically exchange existing advisory fee-eligible mutual fund positions in existing Ambassador Program accounts for a specific mutual fund share class (“Firm selected share class”) in an effort to provide advisory clients with the lowest cost share class available through us. This conversion does not apply to non-wrap eligible, non-billable positions such as C shares or other back-end load shares that may be held in your Ambassador account and which are not eligible for advisory fee billing. We perform ongoing monthly maintenance conversions to ensure the Firm-selected share class has been implemented in your account. These share class conversions are non-taxable events, and your cost basis carries over to the new Firm-selected share class. We retain the 12b-1 fees received from non-wrap eligible, non-billable mutual funds that are not eligible for advisory fee billing. Fees associated with the Firm-selected share class may be greater than or less than the fees of your existing advisory fee-eligible mutual fund position. You should take into consideration fee expenses when transferring mutual funds to us or maintaining mutual fund positions within your advisory account(s). On a periodic basis, we convert class C shares that have been held at least one year or are otherwise no longer subject to the fund company’s CDSC, which is typically 1% of the amount invested, to the Firm-selected share class. The one year holding period is the required minimum holding period typically established by fund companies before the shares become eligible for conversion to another share class without being subject to the CDSC. However, certain funds may require that investors hold the Class C shares longer than or less than one year before these shares are CDSC-free. CDSC-free class C shares held in advisory program accounts automatically convert, on a tax-free basis, to the share class recommended by us on a quarterly basis. For example, a client that holds $50,000 in class C shares purchased 6 months ago that subsequently transfers these shares to his or her Ambassador account is not assessed an advisory fee for 6 months. The shares are subsequently converted by us to the Firm-selected share class the quarter after they are CDSC-free and once converted are subject to advisory fees. Also, upon conversion of the C share to the Firm-selected share class, the 12b-1 fees (if any) are credited to you on a bi-monthly basis. Investments held in Ambassador accounts may be comprised of mutual fund shares only (both load-waived and no-load funds), individual equity and fixed income securities and other investments, or a combination of mutual fund shares and individual securities and other investments. With respect to load funds, only the Firm-selected share class of these funds, for which the mutual fund sales charge has been waived, may be purchased and charged an advisory Fee in these Programs. Clients may hold fund shares in an Ambassador account that were originally purchased in a commission-based account and assessed a front-end load at our Firm. However, we designate these shares as non-billable assets for two years from their original purchase date and generally do not charge an advisory Fee on these assets during this period. Additionally, we credit 12b-1 fees received by us (if any) to your account on a bi-monthly basis. This two-year exclusion period (or “Two Year Rule”) has been implemented by us to avoid clients being assessed both a load or commission and an advisory Fee on the same asset, but only applies to those above-mentioned securities and other investments that were purchased through us. For questions about which assets are billable or non-billable, please consult with your financial advisor. If you purchased a share class designated as non-billable (or “ineligible”) that is subsequently exchanged into a share class that is otherwise eligible for advisory fees (for example, class C shares held for a year (from the trade date where commissions were incurred) and exchanged into a no- load or load-waived class A share as described above), the Two Year Rule will not apply, provided you held the ineligible share class at least one year before converting to an eligible share class and the original load was 1.05% or less or the commission did not exceed $50. The Two Year Rule may create a financial incentive for your financial advisor to recommend you exchange to an advisory fee-eligible share class. However, per the above example of exchanging C shares to load-waived A shares, this incentive is mitigated by requiring that the C shares must be held for at least one year before they are allowed to be exchanged for A shares, where the load associated with C shares is typically 1%. The Two Year Rule is expressly intended to avoid assessing advisory fees on share classes assessed a load in excess of 1%, where the maximum load is typically in excess of 4%. Please refer to the “Non-Billable Assets” section for more information. Certain Alternative Investment Arrangements and Compensation It is important for you to work with your financial advisor(s) to evaluate how a particular alternative investment and its features fit your individual needs and objectives. It is important to note that the fees and expenses related to alternative investments are often higher than those of more traditional investments. An important component of this selection process includes carefully reading the accompanying offering documents and/or prospectus prior to making a purchase decision. The offering documents contain important information that will help you make an informed choice. While each investment differs in terms of both total fees and expenses and how those fees and expenses are calculated, the following section discusses the primary categories of fees and expenses that are common to many alternative investments and the different ways that we and your financial advisor(s) may be compensated. Management Fees The manager for any particular investment often charges a management fee that is based on the total value of your investment. As the value of your investment increases, the total management fees that a manager receives may increase. As the value of your investment decreases, the total management fees that a manager receives may decrease. We and/or your financial advisor may share in a portion of management fees to which an investment manager is entitled. Incentive-Based Compensation Many alternative managers receive incentive-based compensation in addition to management fees. Incentive-based fees typically involve the manager retaining a percentage of profits generated for clients. Fees related to incentive compensation are often referred to as incentive, performance-based fees or carried interest. The exact calculation of incentive fees or carried interest differs by product and manager. Our Firm may share in any incentive-based compensation to which an investment manager is entitled, which can be up to 100% of the incentive fee collected by an investment manager. Upfront or Ongoing Servicing Fees or Placement Fees Many alternative investments have upfront costs directly related to compensating your financial advisor and/or our Firm, generally based on the total amount of your investment, up to 5.5%. Ongoing servicing fees can be as high as 4% of the value of your investment. Redemption Fees Some investments have direct or indirect costs related to liquidating your position, particularly if an investment is liquidated shortly after being purchased or if an investment is specifically designed to provide limited or no liquidity to investors. Redemption fees assessed by a manager can be as high as 5% of your investment. Other Expenses Alternative investment strategies may be accessed through a variety of legal structures, including mutual funds, limited partnerships, and limited liability companies. In certain structures, particularly for new offerings, investors may incur organization and offering expenses that are related to the creation of the legal structure and marketing of the product. These costs ultimately serve to decrease the amount of the client’s investment. Additionally, investors may incur other expenses based on the investment activity of the fund. For instance, in a real estate fund, investors may be charged fees related to the acquisition of a property. In a hedge fund that shorts stock, there are costs associated with establishing and maintaining the short position. Lastly, investors in alternative investments generally bear the cost of certain ongoing expenses related to administration of the product. These expenses may include costs related to tax document preparation, auditing services, or custodial services. Please refer to the offering documents and/or prospectus for fees and other expenses you may incur relating to your investment. Your financial advisor will answer any questions regarding the total fees and expenses and the initial and ongoing compensation that your financial advisor, our Firm and/or our affiliates may receive. Financial Incentives involving co-branded credit cards We offer co-branded credit cards through Elan Financial Services (“Elan”), a company within U.S. Bank. U.S. Bank and RJA are separate and non-affiliated companies. If a client applies for an Elan credit card through us, we receive $100 for each approved application. Our credit card program offers consumer and business credit cards. We also receive 10 basis points on the net amount consumers spend on their consumer credit cards and 15 basis points on the net amount consumers spend on their business credit cards. These payments are made to us by Elan on a periodic basis. The term net refers to the amount of purchases minus returns, chargebacks and refunds. We do not share these payments with your financial advisor. Clients are not under any obligation to apply for a credit card through Elan as a condition of opening an advisory and/or brokerage account through us. For more information about our credit card program, please visit our website at https://www.raymondjames.com/wealth-management/advice-products-and-services/banking-and-lending-services/cash- management/raymond-james-credit-card. Options for Assets Invested in Employer-Sponsored Retirement Plan Accounts If you have an employer-sponsored retirement plan assets, you may have several choices as to what to do with your assets when you retire or change jobs. Providing education to you on the rollover of employer-sponsored retirement plan assets could include discussion of the following general educational topics: 1. General options that may be available to you (e.g., remaining in the employer-sponsored retirement plan if the plan permits, rolling to a new employer-sponsored retirement plan if one is available, rolling to an IRA, or taking out a cash distribution) 2. General information about the significant features of each option 3. Factors you may want to consider in assessing those options. Our Firm and your financial advisor have a financial incentive for you to rollover your assets into an IRA because of the compensation we receive when you transfer funds from an employer-sponsored retirement plan or from another IRA. If you decide to open a brokerage or advisory account, we will be paid on those assets, through commissions or advisory fees. You should be aware that any commissions or advisory fees charged likely will be higher than those fees you paid through your employer-sponsored retirement plan, and there can be additional expenses associated with the account. Please refer to the “Additional Expenses” section for more information. Compensation Associated with Our Cash Sweep Program In the Raymond James Bank Deposit Program (“RJBDP”), the Cash Sweep Program fees paid to us by the participating banks provide a material source of revenue to us and/or our affiliates. In addition to the Fees that we or our affiliates receive from our advisory accounts, this revenue source is integral to financing our or our affiliates’ business activities and helps to contribute to our overall profitability. In addition to the fees we receive from the participating banks, we and our affiliates, including affiliate banks, receive other financial benefits in connection with the Cash Sweep Program. Cash balances provide a relatively low-cost source of funds to us and/or our affiliates through CIP and to RJ Bank and TriState Capital Bank through RJBDP. This revenue and other benefits to our Firm and our affiliates increases when more client funds are held in the Cash Sweep Program. Firm compensation and other benefits RJA and our affiliates receive are described in more detail below, by program:
• RJBDP Sweep Option: o Participating Banks (excluding RJ Bank and TriState Capital Bank): Each participating bank, except RJ Bank and TriState Capital Bank, will pay us and/or our affiliates a fee equal to a percentage of the average daily deposit balance in your account at the bank. The fee from all participating banks paid to us and/or our affiliates may be an annual rate equal to the Federal Funds Target Rate upper limit, plus 75 basis points (0.75%) of all balances in deposit accounts taken in aggregate. The fees we receive vary by bank and by interest rate tier, and those fees will affect the interest rate available to you on your deposit. RJA pays service fees to unaffiliated service providers involved in the RJBDP program out of the fees that RJA receives from the banks. o RJ Bank and TriState Capital Bank: RJ Bank and TriState Capital Bank will pay us and/or our affiliates an annual administrative fee of up to $100 per account. RJ Bank and TriState Capital Bank benefit by receiving deposits through RJBDP on which it pays an interest rate that may be less than the cost of other alternative funding sources available to it. Deposits in deposit accounts at RJ Bank and TriState Capital Bank provide a stable source of deposits for RJ Bank and TriState Capital Bank, which they may use to fund new lending and investment activity, as permitted by applicable law. As with other depository institutions, the profitability of RJ Bank and TriState Capital Bank are determined in large part by the difference between the interest paid and other costs associated with deposits, and the interest or other income earned on its loans, investments, and other assets.
• CIP Sweep Option: After paying interest to clients on their cash in CIP, we and/or our affiliates retain any additional benefit or remuneration related to client cash in CIP. Specifically, for the portion of CIP cash required to be placed in overnight repurchase agreements or deposited in qualifying trust or cash accounts with major U.S. banks, we and/or our affiliates retain any remuneration received from those sources. We and/or our affiliates also retain any remuneration or other benefit received as a result of any CIP cash balances not placed in such investments. Compensation/Benefits Shared with Others With your financial advisor: We and/or our affiliates do not share with your financial advisor any portion of the revenues we and/or our affiliates receive on the aggregate amount of client funds in the Cash Sweep Program. in advisory accounts. However, the aggregate amount of cash in the Cash Sweep Program by all of your financial advisor’s clients may be credited to the financial advisor for purposes of determining the overall payout rate that your financial advisor receives from us. Higher aggregate amounts of client funds in the Cash Sweep Program may cause your financial advisor to receive higher compensation on transactions and activities unrelated to the Cash Sweep Program, even though no Cash Sweep Program revenue is shared with the financial advisor. The interest rate that you receive on your cash in the Cash Sweep Program is not impacted by any such benefit to your financial advisor. With third parties: We or our affiliates may share a portion of the revenues we receive from the Cash Sweep Program with third parties, including but not limited to an introducing broker-dealer or introducing investment adviser. Whether and on what terms any such sharing would occur would be established by contractual agreement between our Firm or our affiliate and the third party. The interest rate that you receive on your cash in the Cash Sweep Program is not impacted by any revenue shared with a third party. Intercompany Payments Between Affiliates Our Firm and our affiliates make certain intercompany payments to compensate each other for performing various administrative and research services. In connection with our mutual fund sales, we or our affiliates receive compensation from Raymond James Investment Management for providing services unrelated to sales of the Carillon Family of Mutual Funds, including (but not limited to) consulting services, marketing services, sponsorship fees, support services, and transfer credits for trade execution services. Intercompany payments received or paid by us or our affiliates may be terminated, modified, or suspended at any time. In connection with the RJRP program, a portion of the Fee assessed by us to participating client accounts is shared with our Equity Capital Markets division for research services or with the Global Wealth Solution division. Buying Securities and other Investments on Margin and Margin Interest Margin involves borrowing money from our Firm to buy securities and other investments. If you use margin (subject to Firm approval based on your stated investment objectives) to buy securities and other investments in your margin account, you will pay interest on the debit balances in your account. The rate varies depending on the size of the average debit balance. In addition, if your account is approved for margin, we can create margin debt in your account as needed to pay monies owed by you, including the Fee and you will be responsible for the interest on any such margin debt. Margin interest generates additional revenue to us and our affiliates. Your financial advisor, our Firm, and/or our affiliates have a financial incentive to recommend its use. When margin is used to buy securities and other investments, the costs you incur and the compensation received by your financial advisor, our Firm, and/or our affiliates, generally increases as the size of the outstanding margin balance increases. Further, you pay more in Fees as the gross value of the account increases. There is no incentive for your financial advisor, our Firm, and/or our affiliates to recommend the liquidation of any asset to pay down a margin debit. Margin borrowing involves additional risks. Margin borrowing results in increased gains if the value of the securities and other investments in the account go up, but increased losses if the value of the securities and other investments in the account goes down. We have the authority to issue a margin call and/or sell securities in the account, in order to maintain the required equity in the account or to liquidate all or part of the account to repay any portion of the margin loan, even if the timing would be disadvantageous to you. Upon approval, where applicable, you receive a Truth In Lending Statement from us disclosing the risks, including an explanation of the details and conditions under which interest is charged, the method of computing interest, and the conditions under which additional collateral may be required. The use of margin will impact your billing as well. For example, let’s assume your account has a long market value of $100,000 and a debit (margin) balance of $20,000. The Account Value for billing would be $100,000, even though the account statement would show a value of $80,000. If you sell a security short (sell a security you do not own) while you have an existing debit (margin) balance in your account, the cash generated from the short sale will decrease your debit balance only if you sold an option short. If you sold an equity security short, the cash generated will not decrease your existing debit (margin) balance. We treat that cash as “restricted” because we will use it to buy the securities sold short and deliver them to the buyer. Please also refer to the Treatment of Short Sale Transactions (Short Equities and Options) and Associated Cash Balances section for additional information. Short Sales We and/or our affiliates earn fees on the short position in your account, which are in addition to the Fee. We and/or our affiliates earn fees when the following occurs: Amount Position Account Value $100,000 Long position Included as $100,000 for billing ($20,000) Debit margin balance as shown on account statement $20,000 not included in Account Value for billing purposes $100,000 Absolute Market Value
• When you borrow a security that RJA can lend from its own inventory or its customers’ securities holdings, you pay a fee to us and/or our affiliates.
• When RJA is unable to lend you securities, RJA may borrow the securities from another firm and split the fee you pay with that firm. For more information on interest/charges you incur associated with margin balances and/or shorts sales, please visit our public website: raymondjames.com/services_and_charges.htm. You may also contact your financial advisor, call us at 800-647-SERV (7378) for additional information, or submit your written request to: Raymond James Client Services, 880 Carillon Parkway, St. Petersburg, FL 33716. Other Compensation RJA and/or our affiliates receive other compensation associated with the sale of certain products as listed below. These compensation arrangements are further described in the “Important Client Information” document located at www.raymondjames.com/ICI or on our public website: https://www.raymondjames.com/legal-disclosures/packaged-product-disclosures. This information is also included as part of your Welcome Kit, which is mailed to your address of record, upon account opening.
• Payment for Order Flow: We route order flow through our broker-dealer. For more information regarding RJA’s order routing practices, please visit our public website: http://www.raymondjames.com/orderrouting.
• Derivative transactions through RJ Capital Services.
• Sale of market-linked certificates of deposit and market-linked notes: Specific fees related to the offering are fully disclosed in the final pricing supplement. For more information, please visit our public website: https://www.raymondjames.com/legal- disclosures/packaged-product-disclosures.
• Sale of Invesco Raymond James SB-1 Equity, refer to the product prospectus for compensation information.
• Sale of equity-linked notes: Specific fees related to the offering are disclosed in the offering documents. For more information, please visit our public website: https://www.raymondjames.com/legal-disclosures/packaged-product-disclosures.
• Licensing fees from UIT sponsors. For more information, please visit our public website: https://www.raymondjames.com/legal- disclosures/packaged-product-disclosures/unit-investment-trusts-at-raymond-james. Other Administrative and/or Service-Related Fees Outside of our E&M Program, we receive compensation from other product sponsors and service providers who offer securities and other investments or services to both affiliated and unaffiliated investment advisers. These payments are intended to compensate us and/or our affiliates for a variety of administrative and/or distribution related services and support. The structure of payments varies among product sponsors and service providers. These payments are generally not disclosed in detail in a particular sponsor's product prospectus where applicable. More information about the other administrative and/or service-related fees paid to us and/or our affiliates by our product sponsors and service providers including but not limited to mutual fund, ETF, annuity, insurance, alternative investment, market-linked investment, and trust sponsors, is available on our public website:https://www.raymondjames.com/legal- disclosures/packaged-product-disclosures. Financial Advisor Compensation As discussed above under the “Advisory Fees” section, a portion of the Fee you pay under each wrap fee Program or Dual Contract Platform described is paid to the Firm and to your financial advisor as compensation for the services by each. Your financial advisor may share portions of his or her compensation with other financial advisors with whom he or she has made certain arrangements. As described more fully below, depending on your financial advisor’s annual revenue generation with the Firm, your financial advisor can receive a higher portion of the Fee paid to the Firm (therefore, the Firm retains less of the Fee paid). As a result, your financial advisor may be incentivized to increase their annual revenue generation with the Firm by recommending products/services of the Firm to obtain higher payout percentages. In addition, one financial advisor’s compensation may be higher or lower than another financial advisor’s based on his or her individual gross revenue. In such cases, the overall Fee paid by you would remain the same pursuant to your advisory agreement, which may include the Master Advisory Agreement. Newly affiliated RJA advisors through our Advisor Mastery Program may receive a salary in addition to Fees (or salary in addition to commissions and trails in the case of brokerage-related transactions) for a period of time. The salary paid by RJA declines each year as the production of the adviser in this program increases. The compensation your financial advisor receives will not change based on the advisory Programs, Dual Contract Platform, or services you select when standard fees are applied. Although standard fees vary amongst the different account programs, Dual Contract Platform, or services offered by us, your financial advisor receives the same percentage of the Fee regardless of the Program, Dual Contract Platform, or services you select. However, the Programs, Dual Contract Platform, or services recommended to you by your financial advisor can impact his or her ultimate compensation if, for example, you are paying less than the standard fee schedule in which case the net amount paid to your financial advisor may vary. As a result of a recommendation to you, and your participation in one of our Programs, Dual Contract Platform, or services, your financial advisor receives compensation from our Firm or other parties as described below. You should be aware of the following about your financial advisor’s compensation as a financial advisor, and in some cases, as a registered representative of RJA, the conflicts of interest created by the financial advisor’s compensation and how we mitigate those conflicts of interest. Your financial advisor’s compensation may be more or less than what your financial advisor would receive if you paid separately for investment advice, brokerage, and other transaction-based services. Your financial advisor may have a financial incentive to recommend a wrap fee Program, Dual Contract Platform, or service rather than recommending an alternative product, program, or service, if comparable or if available separately to clients. The reverse may also be true. The lack of compensation adjustments may provide a disincentive to a financial advisor to recommend a wrap fee Program, Dual Contract Platform, or service over an alternative product, program, or service available to you through us. You should be aware of these arrangements and should consult your financial advisor for additional details regarding their compensation levels in fee-based accounts. We have a fiduciary duty to act in your best interest. To ensure your financial advisor is providing appropriate investment advice, we monitor the appropriateness of existing advisory accounts on an ongoing basis by conducting various reviews, such as account concentration and household account transaction activity. Your financial advisor will also meet with you at least annually to review your investment objectives, risk tolerance, and financial situation. We also encourage you to discuss all available investment options with your financial advisor. Your RJA financial advisor may also receive the following financial incentives: Participation in recognition clubs: At the conclusion of each year, qualifying financial advisors are awarded membership in our recognition clubs. Qualification for recognition clubs is based upon a combination of the financial advisor’s annual production (including both brokerage and advisory), total client assets under administration, and the professional certifications acquired through educational programs. Participation in these recognition clubs represents a conflict of interest since the qualification criteria is based, in part, on the annual gross production of the financial advisor, and as a result, the financial advisor is incentivized to increase his or her gross production (that is, increase commissions and advisory fees) to obtain the required recognition club level. Recognition club members will receive invitations to trips, conferences, and may also receive incentive compensation in the form of cash payments, stock options, and restricted stock units. You should be aware of such arrangements and consult your financial advisor for additional details. Financial incentives for initial/ongoing affiliation with us: In addition to compensation, we provide financial advisors with access to financial incentives for affiliating with our Firm. These arrangements include, but are not limited to, transition assistance, bonuses, deferred compensation arrangements, enhanced pay-outs, repayable business transition or working capital loans, and administrative fee reimbursements. Your financial advisor may also receive compensation related to attendance at our conferences, events, as well as rewards trips, marketing services and materials, payment and reimbursement of certain business expenses and other valuable financial incentives. Based on these arrangements, your financial advisor is incentivized to recommend that you open and maintain accounts for advisory and/or brokerage services. These incentives may influence your financial advisor’s advice that you transition your account(s) to the Firm. Other Forms of Non-Cash Compensation: Our financial advisors may receive promotional items, meals and entertainment, or other non-cash compensation from product sponsors or service providers. Consistent with applicable laws and regulations, these product sponsors or service providers may pay for or provide training and educational programs for our financial advisors and their existing and prospective clients. Product sponsors or service providers may also pay us, directly or indirectly, to offset expenses incurred for due diligence meetings, conferences, client relationship building events, occasional recreational activities, and other events or activities that are intended to result in the promotion of their investment products or services. Non-cash compensation can vary by vendor and event. The receipt of cash and non-cash compensation from product sponsors or service providers may create an incentive for financial advisors to recommend certain investment products or services over others. Other compensation may include:
• Occasional gifts up to $100 per vendor per year
• Occasional meals, tickets, or other entertainment of reasonable and customary value
• Sponsorship support of educational or training events (which include educational events financial advisors may arrange for clients and prospects)
• Seminars and/or payment of expenses related to training and education of employees
• Various forms of marketing support and, in certain limited circumstances, the development of tools used by us for training or record- keeping purposes. Because each advisory Program is distinct and offers a different bundle of services, the Fee paid by you is allocated within the Firm differently from one Program to another. As a result, a financial advisor may have a disincentive to recommend certain of our advisory programs to clients with smaller accounts that otherwise would meet the standard account minimum for each respective advisory Program. Your financial advisor may not offer you all of the Programs, Dual Contract Platform, or services available from us for which you may be eligible to participate. As a result, your investment options and the level of investment diversification you achieve may be limited.