From Sponsors of Mutual Funds, Variable Insurance Contracts, 529 College Savings Plans and Direct Participation Programs And Non-Traded Real Estate Investment Trusts
As an investor, it is important that you have a well-thought-out investment plan to help you meet your investment goals. It is also important for you to understand the sales compensation and certain other fees associated with your investments and the potential conflicts of interest Summit Brokerage Services, LLC (“Summit”) and your registered representative may have when offering and recommending investments to you. This document is intended to help you understand the various forms of compensation that Summit Brokerage Services and your representative earn when you purchase a mutual fund, variable insurance contract, 529 college savings plan, direct participation program or a non-traded real estate investment trust. These various forms of compensation create potential conflicts of interest, and it is important for you to assess potential conflicts of interest before making an investment decision.
Summit Brokerage Services offers a wide variety of investment products, including mutual funds, variable insurance contracts, 529 plans, and direct participation programs and non-traded real estate investment trusts. Product sponsors for these products may compensate Summit Brokerage Services in various amounts for marketing, selling, processing and maintaining your investments in these products and to reimburse expenses for due diligence. These product sponsors also compensate Summit Brokerage Services for training and educating our registered representatives, employees and investors. These compensation arrangements are described in more detail in the prospectus and Statement of Additional Information (SAI) for each mutual fund, in variable insurance contracts, in the plan document for a 529 college savings plan, or in other documents prepared by the product sponsor.
When you purchase an investment, you will usually pay a sales charge. This sales charge may be paid at the time of purchase or the sales charge may be built into the expense of the product and/or charged to you when you sell your investment. Summit Brokerage Services is paid by the product issuer or its affiliates shortly after the transaction. Part of that payment goes to your registered representative, based on a compensation formula agreed to between the representative and Summit Brokerage Services. This compensation formula is the same for all similar products, regardless of the product issuer. Your sales charges and expenses and the sales commissions paid to Summit Brokerage Services differ from investment to investment, and may depend on the amount of money you invest. In addition, after your initial transaction, Summit Brokerage Services is eligible to receive ongoing or continuing compensation, which is sometimes called a 12b-1 fee, service fee, trailing commission or trail and is designed to compensate Summit Brokerage Services for the marketing and services we provide for our representatives and investors. We retain a portion of these fees and pay the remainder to your registered representative, or, in some instances, may pass all of the fees on to your registered representative. You do not pay these fees directly. They are deducted from the total assets in the fund and therefore reduce investment returns. The amount of trail commissions is set by the mutual fund company and is typically set forth in the mutual fund prospectus and/or SAI. Additionally, some of Summit Brokerage Services’ registered representatives work from locations in financial institutions. In that setting, part of the transaction based compensation, including ongoing compensation, is paid to the financial institution at which your registered representative is located (“Financial Institution”) based on a compensation formula agreed to between the Financial Institution and Summit Brokerage Services. The Financial Institution in turn may pass some of this compensation to your registered representative, or we may pay a portion of the compensation received from product issuers directly to your registered representative.
Potential Conflicts of Interest in Transaction-Based Compensation
It is important for you to understand that transaction-based compensation may vary from one product to another, and that Summit Brokerage Services receives and pays a portion of transaction-based compensation to your registered representative. Accordingly, a potential conflict of interest exists where Summit Brokerage Services and your registered representative are paid more if you purchase one type of product as opposed to another, or you purchase from one product sponsor instead of another product sponsor. If you have any questions about the amount of transaction-based compensation Summit Brokerage Services or your registered representative will earn from your investment alternatives, you should discuss them with your registered representative. More information about these investment products and transaction-based compensation is available on our web site.
Mutual Fund and Variable Insurance Contract Revenue Sharing and the Strategic Partners Program
Although Summit Brokerage Services offers thousands of mutual funds from more than 250 mutual fund companies, and hundreds of variable life and annuity contracts from more than 100 insurance companies, we concentrate our marketing and training efforts on those investments offered by a much smaller number of select and well-known companies (Strategic Partners). Strategic Partners are selected, in part, based on the competitiveness of their products, their technology, their customer service and their training capabilities. Strategic Partners have more opportunities than other companies to market and educate our representatives on investments and the products they offer. For a list of our Strategic Partners, please see Strategic Partners.
Our Strategic Partners pay extra compensation to Summit Brokerage Services and/or its affiliates in addition to the usual product compensation described in the prospectus. The additional amounts Strategic Partners pay us vary from one Strategic Partner to another and from year to year. Some Strategic Partners pay up to 45 basis points (0.45%), of your total purchase amount of a mutual fund or variable insurance product. So, for example, if you invest $10,000 in a mutual fund, Summit Brokerage Services could be paid up to $45. Additionally, some Strategic Partners make a quarterly payment or additional quarterly payment based on the assets you hold in the fund or variable insurance product over a period of time of up to 15 basis points (0.15%) per year. For example, on a holding of $10,000, Summit Brokerage Services could receive up to $15. Alternatively, we may receive compensation from the mutual fund or insurance company as: (1) a flat fee regardless of the amount of new sales or assets held in client accounts; or (2) the greater of such flat fee or amount based on assets and/or new sales as referenced above and any ticket charge payments referenced below. These payments are designed to compensate Summit Brokerage Services for ongoing marketing and administration and education of its employees and representatives. You do not make these payments. They are paid by the mutual fund and insurance companies and/or their affiliates out of the assets or earnings of the funds or insurance companies or their affiliates. It is important to note that you do not pay more to purchase Strategic Partner mutual funds or insurance products through Summit Brokerage Services than you would pay to purchase those products through another broker-dealer, and your representative does not receive additional compensation for selling a Strategic Partner product.
1. "Basis point" is a common term used to describe compensation and other costs relating to securities. A basis point is one one-hundredth of a percentage point.
2. Summit Brokerage Services also may receive revenue sharing payments from companies that are not Strategic Partners.
Potential Conflicts of Interest in Receiving Revenue Sharing from Strategic Partners
A potential conflict of interest exists in that Summit Brokerage Services is paid more revenue-sharing fees if you purchase one type of product instead of another and/or you purchase a product from one particular sponsor instead of another. Your representative also indirectly benefits from Strategic Partner payments when the money is used to support costs relating to product review, marketing or training, or for waiver of ticket charges, as described below. Summit Brokerage Services' financial advisors do not receive any compensation associated with the payments noted above.
Mutual Fund Ticket Charges
When you purchase a mutual fund of a Strategic Partner in a Pershing brokerage account, Summit Brokerage Services may absorb the nominal “ticket charge” for each transaction of approximately $30 which would normally be paid by you or your registered representative. Generally, the mutual fund families that participate in the Strategic Partner Program subsidize some of these ticket charges through the compensation mentioned above or by paying us a per trade fee of up to $10. The type of transaction in a Strategic Partner mutual fund purchase that may qualify for a ticket charge waiver varies depending on the particular Strategic Partner. In general, the ticket charge will be waived for the purchase of certain mutual funds in an amount of $2,500 or more. Every mutual fund offered by Summit Brokerage Services may be purchased without a ticket charge by processing the transaction with a check and application sent directly to the mutual fund company. We believe that these ticket charge waivers do not compromise the advice your representative provides to you.
First Clearing and Pershing Relationship
First Clearing and Pershing are the clearing firm for Summit Brokerage Services’ brokerage business. Due to this business relationship, First Clearing and Pershing share with us a portion of the commissions and fees you pay to First Clearing and Pershing. Also, First Clearing and Pershing may provide consulting and other assistance to Summit Brokerage Services. We may also participate in other revenue First Clearing and Pershing are paid on the assets held in your account. The following is a brief description of some of the revenue items received from First Clearing and Pershing. First Clearing and Pershing receive revenue from money market funds, and may share that revenue with Summit Brokerage Services for money market funds made available to you for cash sweeps in your brokerage account. Summit Brokerage Services may share some of the revenue received from First Clearing and Pershing with your registered representative. Additionally, Pershing may also pay us a share of the service fees it receives from mutual fund companies that participate in Pershing’s FUNDVEST® no-transaction-fee program. Under the FUNDVEST® program many no-load mutual funds may be purchased subject to program requirements and other restrictions.
Direct Participation Programs and Alternative Investment Products
Summit Brokerage Services, through its representatives, offers its clients a wide variety of direct participation programs and alternative investment products including: non-listed real estate investment trusts; limited partnerships; 1031 exchange programs; business development companies; and oil and gas programs (collectively “Alternative Investment Products”). In addition to commissions Summit Brokerage Services receives from the sale of Alternative Investment Products, we may receive marketing allowance payments from sponsors of Alternative Investment Products. While the additional compensation we receive as well as the arrangements we have varies with each sponsor of an Alternative Investment Product, some sponsors may pay a marketing allowance fee of (i) up to 20 basis points (0.20%) annually on assets held in the Alternative Product or (ii) up to 150 basis points (1.50%) on the gross amount of each sale, depending on the product. These payments are designed to compensate us for ongoing marketing and administration as well as education of our employees and representatives regarding these types of products. You do not make these payments. They are paid by the product sponsor out of the assets or earnings of the product sponsor. It is important to note that you do not pay more to purchase products through us than you would pay to purchase those products through another broker-dealer, and your representative does not receive additional compensation for selling products from sponsors that pay us such additional compensation. A potential conflict of interest exists in that Summit Brokerage Services is paid more revenue-sharing fees if you purchase one type of product instead of another and/or you purchase a product from one particular sponsor instead of another. Your representative also indirectly benefits from these sponsor payments when the money is used to support costs relating to product review, marketing or training. If you have any questions about any portion of this document, please feel free to discuss them with your registered representative or call 888.972.7560. For a current list of the Alternative Product sponsors that pay us additional compensation, please see Alternative Product Sponsors.
Training and Education Compensation
Summit Brokerage Services and its representatives also receive additional compensation from mutual fund and insurance companies, including Strategic Partners, and issuers of Alternative Investment Products, that is not related to individual transactions or assets held in accounts. This money is paid, in accordance with regulatory rules, to offset up to 100% of the costs of training and education of our representatives and employees. In some instances, mutual fund and insurance companies and issuers of Alternative Investment Products may pay a flat fee in order to participate in a Summit Brokerage Services training and educational meeting. These meetings or events provide our representatives with comprehensive information on products, sales materials, customer support services, industry trends, practice management education, and sales ideas. It is important to note that due to the number of mutual fund products, variable insurance products, and Alternative Investment Products that Summit Brokerage Services offers, not all product sponsors have the opportunity to participate in these training and educational events. In general, our Strategic Partners and Alternative Investment Product sponsors have greater access to participation in these events and therefore greater access to, and opportunity to build relationships with, our representatives. Some of the training and educational meetings for which we or our representatives receive reimbursement of costs may include client attendance. If you attend a training or educational meeting with your registered representative and a product sponsor is present, you should assume that the product sponsor has paid for all or a portion of the costs of the meeting or event.
Other Cash and Non-Cash Compensation
In addition to reimbursement of training and educational meeting costs, Summit Brokerage Services and its representatives may receive promotional items, meals or entertainment or other non-cash compensation from representatives of mutual fund companies, insurance companies, and Alternative Investment Products, as permitted by regulatory rules. Additionally, sales of any mutual funds, variable insurance products and Alternative Investment Products, whether or not they are those of Strategic Partners , may qualify our representatives for additional business support and for attendance at seminars, conferences and entertainment events. Further, some of our home-office management and certain other employees may receive a portion of their employment compensation based on sales of products of Strategic Partners and/or certain sponsors of Alternative Investment Products.
Exchange Traded Products Partner Program
Effective July 24, 2018, Summit launched an exchange traded products partner program (ETP Partner Program), which as described below, has similar features to the firm’s Strategic Partner Program. Summit currently has one ETP Partner, WisdomTree Asset Management, but intends to add additional ETP Partners on an ongoing basis. For the most current list of our ETP Partners, please refer to our website, www.summitbrokerage.com, or contact your registered representative.
Although we offer thousands of exchange-traded products (ETPs), we concentrate our marketing and training efforts on those investments offered by select and well-known ETP Partners. An ETP Partner is selected, in part, based on the competitiveness of its products, technology, customer service and training capabilities. An ETP Partner has greater exposure to our registered representatives (e.g., at conferences), and more opportunities to market and educate our registered representatives on investments and the products they offer.
An ETP Partner pays extra compensation to us and/or our affiliates in addition to the compensation described in the prospectus. The additional amounts may vary from one ETP Partner to another and from year to year. In general, an ETP Partner pays us the greater of an annual flat fee regardless of the amount of new sales or assets held in client accounts or up to 0.25% of the ETP’s net expense ratio (as set forth in the prospectus or supplement) of your investment’s average daily balance during the quarter. So, for example, for each $10,000 average quarterly daily balance of an ETP Partners’ product held by our clients, we would be paid up to $25 on an annual basis. Further, if the annual flat fee were $500,000 and the total asset-based fee did not reach that amount, we would still be paid $500,000.
These payments help compensate us and our affiliates for maintaining our platform and providing ongoing marketing, administration and education to our employees and registered representatives. The payments are paid by the ETP Partner and/or their affiliates out of the assets or earnings of the ETP Partner or their affiliates. You do not pay more to purchase an ETP Partner’s product through us than you would pay outside of the ETP Partner Program, and your registered representative does not receive additional compensation for selling an ETP Partner product. For the most current description of the compensation we receive from ETP Partners, please refer to the Firm’s website at, www.summitbrokerage.com.
A conflict of interest exists in the recommendation of ETP Partner products since we receive additional revenue if you purchase an ETP Partner product and/or if you purchase a product from one particular sponsor instead of another. Your registered representative also indirectly benefits from ETP Partner payments when the money is used to support costs relating to product review, marketing or training, or for waiver of ticket charges, as described below. Our registered representatives do not receive any compensation associated with the revenue sharing payments.
When you purchase a Wisdom Tree ETP product in an advisory program offered by Summit Financial Group, we absorb the nominal “ticket charge” (sometimes referred to as a transaction charge) for each transaction, which would normally be paid by you or your representative. In general, the ticket charge will be waived for the purchase of certain ETPs in an amount of $5,000 or more. For Summit Financial Group’s Elite program and select accounts in the Managed Asset Planning program, these ticket charge waivers result in a conflict of interest between you and your investment adviser representative because your representative has a financial incentive to recommend an ETP Partner product that does not assess transaction charges over an ETP that does. We believe that these ticket charge waivers do not result in a conflict of interest between you and your investment adviser representatives in other advisory programs.
In general, if you are not
comfortable with the use of ETP Partner products in your account and the
resulting conflicts of interest, then you should notify your representative of
this preference and you should not participate in any advisory program that
includes ETP Partner products.
Retirement Strategic Partners Program
Summit Brokerage Services may also receive certain revenue sharing payments from third-party firms, including plan recordkeeping platforms as well as investment managers of mutual funds and the issuers of annuities (each a “Retirement Partner”). Retirement Partners participate in activities that are designed to help facilitate the distribution of their products and services, such as marketing activities and educational programs, including attendance at conferences and presentations to Summit Brokerage Services' financial advisors. These revenue sharing payments are in the form of a fixed dollar amount that does not depend on the amount of the Plan’s investment in any product or utilization of any Retirement Partner’s services. Retirement Partners may also pay Summit Brokerage Services' expenses, or provide non-cash items and services, to facilitate training and educational meetings for the Summit Brokerage Services’ financial advisors, which similarly do not depend on the amount of the Plan’s investment in any product or utilization of any Retirement Partners’ services. Our representatives do not receive any portion of these payments. For a list of our current Retirement Partners, please see Retirement Partners. It is important to note that you do not pay more to purchase Retirement Partner products or services through Summit Brokerage Services, than you would pay to purchase those products or services through another broker-dealer, and your representative does not receive additional compensation for selling or recommending a Retirement Partner product or service.
In addition to commission-based compensation for sales of 529 plans, 529 plan assets are included in the amount of total mutual fund or variable annuity assets for which revenue sharing is paid as described above. Summit Brokerage Services does not separately account for these payments and does not have any 529 Plan Strategic Partners.
Revised February 2017