Stifel
Century Securities Associates, Inc.

ERISA Section 408(b)(2) Online Disclosure Notice

This Online Disclosure Notice describes the compensation received by Stifel and Century Securities Associates, Inc. ("Century") (Stifel and Century hereafter collectively referred to as the "Firms") with respect to the services provided by the Firms to your ERISA qualified retirement plan (the "Plan").

Description of the Firms and How to Contact Us

Your Plan maintains or may maintain a securities brokerage account or accounts with Stifel or Century. Stifel and Century are securities broker-dealers registered with the U.S. Securities and Exchange Commission, both firms having headquarters located at 501 N. Broadway, St. Louis, MO 63102. If you have questions regarding the services and/or compensation related to your Plan after reviewing this Online Disclosure, please send an inquiry to our ERISA 408(b)(2) Disclosure questions mailbox at 408b2Inquiries@stifel.com.

Description of Services Provided by the Firms to the Plan

Pursuant to our agreement with you, and upon your direction, Stifel or Century has opened or will open a brokerage account on behalf of the Plan and/or a separate brokerage account for each Plan participant. The Firms provide non-fiduciary, non-discretionary investment-related brokerage services that are intended to assist you with your duties as the responsible fiduciary of your Plan. These services are provided by your Financial Advisor as a registered representative of Stifel or Century. Services may include effecting securities transactions directed by the Plan and/or its participants; providing general research, financial information, and data to the Plan to assist the Plan in its selection and monitoring of specific investments; meeting with the Plan to review investment information, investment performance, fee and expense analyses, and services for the Plan; and educating the Plan or participants on investment issues.

Description of Compensation Paid to the Firms

The Firms may receive various forms of compensation related to the services it provides to your Plan and depending upon the investments selected in the brokerage account.

A. Direct Compensation Paid to the Firms from the Plan
Stifel Brokerage Accounts are subject to applicable fees on the Stifel Fee Schedule.

If your plan utilizes a Stifel sponsored plan document prototype, your accounts are charged an annual fee. See Stifel Fee Schedule.

The following is a list of securities that may be traded in your brokerage account for which the Firms may receive direct compensation. Click on the securities that your plan account(s) owns for a description of the forms and amounts of indirect compensation that the Firms may receive.

1. Equity securities

Equity securities represent an ownership interest in the issuing entity. Equity securities include common stock, American Depository Receipts (ADRs) and closed-end mutual funds made up of equity investments. The firms are compensated for equity securities purchased or sold on a commission basis depending upon the quantity of shares or units purchase or sold and their respective prices. Detailed information on commissions paid to the Firms are included on the specific trade confirmations you receive.

2. Exchange Traded Funds

Exchange traded funds ("ETFs") are typically registered unit investment trusts (described elsewhere on this website) or open-end investment companies, the shares of which represent an interest in a portfolio of securities. ETFs typically trade throughout the day on an exchange at prices established by the market. The firms are compensated for ETFs purchased or sold on a commission basis depending upon the quantity of shares or units purchased or sold and their respective prices. Detailed information on commissions paid to the Firms are included on the specific trade confirmations you receive.

3. Exchange Traded Notes

Exchange traded notes ("ETNs") are senior, unsecured, unsubordinated debt securities typically issued by a bank that are typically linked to the performance of a market index, less investor fees. The firms are compensated for ETNs purchased or sold on a commission basis. Detailed information on commissions paid to the Firms are included on the specific trade confirmation you receive.

4. Fixed Income Securities

Fixed income securities are investments that provide a return in the form of fixed periodic payments and eventually the return of principal at maturity or when the security is "called" by its issuer. All fixed income products when initially offered have their own official statements or other disclosure materials from the issuer, which are available from your Financial Advisor. Fixed income securities include certificates of deposit, corporate bonds, municipal bonds, convertible securities, federal agency bonds, mortgage-backed securities, preferred stock and U.S. Treasuries. The firms are compensated for fixed income securities purchased or sold on a principal basis by either "marking up" (on the plan's purchase) or "marking down" (on the plan's sale) the price of the security paid or received by the account owner. The amount of the "mark up" or "mark down" can range between 0.01% and 2.875%, and averages approximately 1.0% on all fixed income securities trades done at the Firms. Fixed income securities sold on an initial offering are typically sold at "par" (i.e., face value), with the Firms receiving compensation as described in the official statement or disclosure materials from the issuer. Fixed income securities may be sold on an agency basis under which the Firms are compensated on a commission basis. Detailed information on commissions paid to the Firms is included on the specific trade confirmations you receive.

5. Options

Options are securities contracts that give the holder of the contract the right to buy or sell an asset tied to the contract (e.g., stock, indexes, commodities) at a given price within a given period. The Firms are compensated for options purchased or sold on a commission basis depending upon the number of contracts and the principal amount of the trade. Detailed information on commissions paid to the Firms is included on the specific trade confirmations you receive.

B. Indirect Compensation Payable to the Firms from Sources Other than the Plan
The following is a list of securities that may be traded in your brokerage account for which the Firms receive indirect compensation. Click on the securities that your plan account(s) owns for a description of the forms and amounts of indirect compensation that the Firms may receive.

1. Alternative Investments

Alternative Investments include private equity funds, partnership interests, hedge funds, "funds-of-funds," and other forms of investment vehicles that may not be registered with the U.S. Securities & Exchange Commission (collectively, "Funds"). Stifel's compensation with respect to a Fund varies depending on whether or not Stifel is the manager and/or general partner of the Fund ("Stifel Sponsored"). With respect to Stifel Sponsored Funds, Stifel receives the management fees and, to the extent applicable, any performance-based fees or administration fees that your plan pays to the Fund, in each case as specifically set forth in the Fund offering documents that you received prior to investing in the Fund. For non-Stifel Sponsored Funds, Stifel may receive from the Fund placement fees, up-front sales loads and/or back-end sales loads as set forth in the Fund offering documents. Stifel may also receive from the Fund manager or general partner a referral or solicitor's fees, or may receive a share of the management or similar fees that your plan pays to the Fund, which the Fund in turn pays to its manager or general partner. Stifel's compensation from the Fund manager or general partner generally is set forth in the Disclosure Statement provided to you and acknowledged by you prior to investing in the Fund.

2. Collective Investment Trusts

Collective investment trusts are investment funds available generally to institutional investors that pool investor assets for the purpose of larger investments by the trust. The Firms are compensated on a fee basis that can range between zero percent (0%) and one percent (1.0%). Detailed information on compensation and fees associated with collective investment trusts is set forth in the offering disclosure documentation provided by the specific trust.

3. Exchange Liquidity Credits and Fees

Many stock exchanges provide credits, or charge fees, on orders placed with the exchange that add or remove (respectively) liquidity from the exchange. These credits and fees are netted and thereafter Stifel receives a payment from, or is charged a fee by, the exchange based upon the overall effect of the firm's activity upon the exchange's liquidity in a given period. Given the nature of the equity marketplace, the speed in which equity trades are executed (typically milliseconds), and the possibility that a given order may be filled across several exchanges, it is extremely difficult to identify whether a given customer's order either added liquidity to (resulting in a credit) or removed liquidity from (resulting in a fee) the exchange(s) at the time of execution. Likewise, depending on market conditions at the time of execution, each individually executed lot that contributes to completing a full order could result in charges, rebates, or a combination of both.

4. Fixed Annuities

Fixed Annuities are contracts issued by insurance companies that allow the annuitant a fixed return for the life of the annuity. Like any annuity, the annuitant buys into a policy, either with a lump sum or premiums over a period of time. When the annuitant reaches a certain age, or retirement (whichever is greater), he/she begins to receive payments.
Sales commissions are paid to the Firms from the insurance company's assets and range from 1% to 6% of the premium paid into the contract.
Contingent Deferred Sales Charge (CDSC) is charged if an investor withdrawals funds prior to a stated date, typically within 1 to 10 years of purchase date. This fee is deducted from the amount withdrawn and ranges from 5% to 9% in the first year and gradually decreases over the term of the CDSC period. Any CDSC charged is not paid to the Firms.
For more information about sales charges on fixed annuity contracts you own, please email your inquiry. Please have a copy of your most recent Stifel or Century account statement available so that you can identify the correct contract owned.

5. Life Insurance

Life insurance contracts are issued by insurance companies where, in exchange for a premium, the insurance company pays a certain benefit to the survivors of the policyholder upon his/her death.
Sales commissions are paid to the Firms from the insurance company's assets and range from 50% to 70% of the target premium paid into the contract.
Residual Commissions (often referred to as "Trail Commission") are paid to the Firms on an ongoing basis from the insurance company's assets and range from 1% to 10% of assets.
Contingent Deferred Sales Charge (CDSC) is charged if an investor withdrawals funds prior to a stated date, typically within 10 to 20 years of purchase date. This fee is deducted from the amount withdrawn and ranges from 10% to 100% during the first year, and gradually decreases over the term of the CDSC period. Any CDSC charged is not paid to the Firms.
For more information please refer to the contract issued from the life insurance company.

6. Money Market Sweep Funds

When cash balances exist in eligible securities accounts, they may be automatically deposited through a money market sweep service into select money market funds, such as the Dreyfus or Federated Funds most often used as the Firms money market sweep option to assist the liquidity needs of clients.

The Firm receives fees from Dreyfus that are derived from a combination, as applicable, of a fund’s 12b-1 and shareholder services fees, and sub-accounting charges, in addition to the past profits of Dreyfus or its parent company, The Dreyfus Corporation. This fee may be at an aggregate annual rate as high as 0.91% and is paid based on the level of the Firms’ clients’ assets in a fund account. The Firm receives fees from Federated that are derived from a combination, as applicable of a fund’s 12b-1 and shareholder service fees, and supplemental payments. This fee may be at an aggregate annual rate as high as 0.35% and is paid based on the level of the Firms’ clients’ assets in fund accounts. Please see each Dreyfus or Federated Fund’s Prospectus.

7. Mutual Funds

An open-end mutual fund is an investment company that pools money from shareholders with a similar objective and invests in a diversified portfolio of securities with the goal of achieving that stated investment objective. Mutual funds are generally offered in different share classes or pricing structures that provide shareholders the flexibility to select a structure that best meets their investment time horizon and service and support needs. Although the different share classes represent interests in the same portfolio, each share class or pricing structure will have different fees and expenses that impact investment performance.
Sales Charges , as applicable, are paid by the investor and are typically expressed as a percentage of the fund's offering price. Some mutual funds are characterized by having a "front-end" sales charge or "load" in which the sales charge is deducted at the time of the original investment, and then the remaining portion is invested in the fund. All or a portion of the sales charge will generally be paid to the Firms. Other funds have a "deferred" or "back-end" sales charge otherwise known as a "Contingent Deferred Sales Charge" or CDSC. In this case, the sales charge is assessed upon redemption if the investment is not held for a prescribed time period. Any CDSC charged is not paid to the Firms.
For more information please refer to the "fees and expenses" or similar section of the mutual fund prospectuses previously provided to you or click here to go directly to a list of fund companies available at the Firms and a link to their individual websites. Please have a copy of your most recent Stifel or Century account statement available so that you can identify the correct prospectus based on the specific share class and fund(s) owned.
Service Fees (commonly known as "12b-1 Fees") may be paid by funds to compensate the Firms for providing distribution-related, administrative and informational services, as applicable, associated with the funds owned by the Plan. Service Fees are included in the "annual operating expenses" or "expense ratio" charged and reported by each fund, and such amounts are deducted directly from the funds automatically.
Please note that for some funds, the 12b-1 fee expense reported in the prospectus may be lower (by a difference of .01% or .02%) than the amount actually paid by the fund to Stifel. In such cases, the difference is the result of the fund having some accounts that do not have an assigned Financial Advisor to whom the fund pays a 12b-1 fee. Therefore, since the fund does not incur the expense on those accounts, the overall 12b-1 fee reported in the fund prospectus is slightly reduced.
For more information about 12b-1 fees attributable to your Plan, please refer to the mutual fund prospectuses previously provided to you or click here to go directly to a list of fund websites. Please have a copy of your most recent Stifel or Century account statement available so that you can identify the correct prospectus based on the specific share class and fund(s) owned.
Revenue Sharing Stifel may receive compensation from the funds for providing ongoing marketing, training, and education to the Firms' Financial Advisors with respect to the mutual fund sponsor and its products. These revenue sharing payments are in addition to the sales charges, 12b-1 fees and deferred sales charges in the funds' prospectus fee table. Revenue Sharing is generally paid from the fund manager's assets and does not directly reduce the amount invested by the Plan or the Plan's investment earnings. Not all fund companies pay Stifel revenue sharing, and Revenue Sharing that is paid to Stifel varies by fund company.
Amount- The compensation that Stifel receives from those that do make such payments is a combination of up to 0.10% annually of new investments and a maximum of 0.08% annually on assets under management. The Revenue Sharing payments paid to Stifel are subject to volume discounting, such that as total assets placed by the Firms' clients at a fund company increase, the basis points paid for those assets will decrease. Additionally, some fund families may make fixed payments in addition to the above payments or instead of those payments. Financial Advisors at the Firms are not required to recommend any fund providing additional compensation, nor do Financial Advisors directly share in any of the Revenue Sharing fees received.
For more information about revenue sharing compensation, please refer to the "other payments to dealers and financial intermediaries" or similar section of the mutual fund prospectus previously provided to you or click here to go directly to a list of fund families from which Stifel receives revenue sharing payments.
Sub-Accounting Fee Reimbursements
Funds may compensate Stifel for providing record-keeping and related services associated with funds held in a brokerage account. Stifel processes some mutual fund business with fund families on an "omnibus" basis, which means Stifel consolidates the Firms' clients' trades into one daily trade with the fund, and therefore maintains all pertinent individual shareholder information for the fund. The compensation for these services is commonly referred to as "omnibus fees" and is paid by certain funds to Stifel. Not all fund companies pay Stifel Sub-Accounting fees and Sub-Accounting fees that are paid to Stifel vary by fund company. Any Sub-Accounting payments made to Stifel are paid from investor assets in the mutual funds, but in some cases may be subsidized in part by affiliates or the distributor of the mutual funds.
Amount- Stifel generally receives Sub-Accounting fees of $16-$19 per year per fund position held in a commission-based brokerage account, although certain share classes may pay less or nothing at all. Financial Advisors at the Firms are not required to recommend any fund providing additional compensation, nor do Financial Advisors share in any of the Sub-Accounting fees received.
For more information click here to go directly to a list of fund families from which Stifel receives sub-accounting fees.
Networking Fees
Fund families that are not traded omnibus at the Firms are traded on a networked basis, which means Stifel submits a separate trade for each individual client to the fund and therefore Stifel maintains certain elements of the shareholder information. Funds may compensate Stifel for providing these services. Not all fund companies pay Stifel Networking Fees and Networking Fees that are paid to Stifel vary by fund company. Any networking fees paid to Stifel are deducted from the fund manager's assets, but in some cases may be subsidized in part by affiliates or the distributor of the funds.
Amount- Networking reimbursements received by Stifel range from $3-$12 per year per fund position. Financial Advisors at the Firms are not required to recommend any fund providing additional compensation, nor do Financial Advisors share in any of the Networking Fees received.
For more information click here to go directly to a list of fund families from which Stifel receives networking fees.

8. Unit Investment Trusts

Unit Investment Trusts ("UITs") are investment companies sold initially under prospectus. UITs are structured with specific maturity dates (termination dates). The term of a UIT can range from 13 months to more than 25 years. Because UITs are not managed, they typically incur lower annual operating expenses than mutual funds, but have sales charges. The expenses, sales charges and fees associated with a UIT are outlined in its prospectus and can vary depending upon volume breakpoints, rollover discounts and other factors specific to each UIT. The Firms are compensated for a UIT purchase in the form of a concession from the issuer in the range of approximately .65% to 4.00% of the principal value with a current average of 2.60%. Amounts on individual transactions are subject to reduction due to breakpoints that are based on transaction size. In addition, discounts of 1.00% may be given when rolling the proceeds from one UIT to another. Stifel also receives additional concessions from Advisor's Asset Management, First Trust, Guggenheim, and Invesco in the form of volume rebates on a monthly or quarterly basis. These rebates currently range from approximately .05% to .13% of principal value with an average of .10%.
For further details and information, please refer to the investment prospectus for a specific UIT.

9. Variable Annuities

Variable Annuities are a contract offered by an insurance company to which one makes contribution(s) and immediately or later begins receiving payments, which usually last the remainder of the annuitant's life, the amounts of which are in part dependent on the performance of a portfolio of mutual funds.
Sales Charges or commissions are paid to the Firms by the insurance company from their assets. Sales commissions are received by the Firms as a percentage of the premium paid into the contract. This compensation can vary in a range from 1% to 7.5% of the premium paid into the contract.
Service Fees (commonly known as "12b-1 Fees") may be paid by funds in variable annuity subaccounts to compensate the Firms for providing distribution-related, administrative and informational services, as applicable, associated with the subaccounts investments. Service Fees are included in the "annual operating expenses" or "expense ratio" charged and reported by each fund. Service Fees range from .25% to 1.50% of the current value of the contract.
Contingent Deferred Sales Charge (CDSC) is charged if an investor withdrawals funds prior to a stated date, typically 4 to 7 years from purchase date. This fee is deducted from the withdrawn amount. The CDSC will dissipate over a period of a few years to 0%. The CDSC typically ranges from 5% to 9% of the amount withdrawn. Any CDSC charged is not paid to the Firms.
Revenue Sharing Stifel may receive compensation from the insurance company for providing ongoing marketing, training, and education to the Stifel Financial Advisors with respect to the carrier and its products. These revenue sharing payments are in addition to the sales charges, 12b-1 fees and deferred sales charges in the fund's prospectus fee table. Revenue Sharing is generally paid from the Fund manager's assets and does not directly reduce the amount invested by the Plan or the Plan's investment earnings. Not all insurance companies pay Stifel Revenue Sharing, and Revenue Sharing that is paid to Stifel may vary by insurance company. The compensation that Stifel receives from those that do make such payments is a combination of up to 0.15% annually of new investments and a maximum of 0.05% annually on assets under management. Click here to go directly to a list of insurance carriers from which Stifel receives Revenue Sharing payments. No revenue sharing is paid to Century Securities.
For more information please refer to the variable annuity prospectus previously provided to you

C. Compensation Paid Among Related Parties.
Stifel, as a self-clearing broker-dealer, provides securities trading, processing, execution, and other services to Century, as an introducing broker-dealer.

Stifel receives compensation from Century on a transactional basis for securities trade and processing services provided by Stifel to Century as follows:

  • $12.00 per order for Listed Equities, OTC Equities, and Options
  • $25.00 per order for Corporate, Municipal, and Treasury Bonds; Government Agencies; and UITs
  • $15.00 per order for Mutual Fund purchases and sales
  • $5.00 per Mutual Fund Exchange
  • $25.00 per notification of Option exercise or assignment
  • $5.00 per cancel & rebill

Stifel receives compensation from Century on a transactional basis for securities trade execution services provided by Stifel to Century as follows:

  • $.01/share for Listed Equities (non third-market)
  • $1.25/contract for Listed Options
  • $1.00/bond for Listed Bonds

Century receives a rebate from Stifel upon money market balances introduced to Stifel by Century depending upon the overall amount of such money market funds. Such rebates are calculated and paid on a monthly basis and range between 0.30% and 0.45%, depending on the total amount of money market balances. Century representatives do not receive any compensation as a result of such rebates.

D. Compensation for Termination of Services. If your Plan utilizes the Stifel sponsored plan document prototype, each Plan account may be charged a termination fee. Click here for more information.

The Firms do not charge any other additional compensation in connection with the termination of the Plan's services.

Scope of Disclosure

The information provided herein is intended to address the disclosure requirements under Section 408(b)(2) of the Employee Retirement Income Security Act of 1974, as amended (ERISA). Your Plan may incur other service charges that are not payable to the Firms. Such charges may include any expenses, fees and other costs payable to the Plan's administrative service providers, the cost for auditing the Plan's financial statements, and other related expenses. Information regarding these other service charges must be obtained from the applicable service provider. The information included herein provides important information for plan fiduciaries; however, is not intended to create, replace, or modify any existing or prospective agreement with the Firms that may exist now or in the future.