This Online Disclosure Notice describes the compensation received by Stifel and Stifel Independent Advisors, LLC (Stifel Independent Advisors) (Stifel and Stifel Independent Advisors hereafter collectively referred to as the "Firms") with respect to the services provided by the Firms to your ERISA qualified retirement plan (the "Plan") which is or will be established directly at a mutual fund recordkeeping platform . The Firms are not the custodian of the Plan assets.
The Firms
The Firms are securities broker-dealers registered with the U.S. Securities
and Exchange Commission , both firms with headquarters located at 501 N. Broadway,
St. Louis, MO 63102. The Firms provide certain services on behalf of your Plan as
described below in Description of Services. These services are provided by your
financial advisor as a registered representative of one of the Firms.
Description of Services
The Firms provide non-fiduciary, non-discretionary investment-related
brokerage services to your Plan. Services may include providing general research,
financial information and data to the Plan to assist the Plan in its selection and
monitoring of a recordkeeping platform and its specific investment options; meeting
with the Plan to review investment information, investment performance, fee and
expense analyses, and services for the Plan; and educating the participants on investment
issues.
Direct Compensation Payable to the Firms from the Plan
The Firms do not receive any compensation directly from your Plan.
Indirect Compensation Payable to The Firms From Sources Other than the Plan
As registered broker-dealers, The Firms receive payments from the Plan's investment
funds as indirect compensation for the investment-related services provided on behalf
of the Plan. Funds may include mutual funds, stable value funds, bank collective
funds and other similar investment products. Indirect compensation may include:
Sales Charges 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 refer to the recordkeeping company's
proposal or the "fees and expenses" or similar section of the mutual fund prospectuses
or click here to go directly to a list of fund company websites.
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, please refer to the mutual fund prospectuses or click here to
go directly to a list of fund websites.
With some recordkeeping platforms, Stifel may not receive the full amount of such 12b-1 fees. The gross amount of the 12b-1 fees are paid directly to the plan's recordkeeping platform and its related broker dealer. A net amount or "level compensation" across all funds on the platform is paid to the Firms. This net level amount is indicated in your recordkeeping service agreement or contract.
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 funds 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 the
Firms' assets under management. The revenue sharing payments paid to Stifel are
subject to volume discounting, such that as total assets placed by the Firms 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.
Compensation Paid Among Related Parties
Stifel receives indirect compensation from the Plan, and may receive revenue sharing
payments from the Manager of a fund. These payments are not shared with any entities
affiliated with Stifel or with any other entities.
Stifel Independent Advisors receives indirect
compensation from the Plan's funds. These payments to Stifel Independent Advisors are divided between
Stifel Independent Advisors and your registered representative (as an independent contractor), with
Stifel Independent Advisors receiving between 10% to 40% of the total compensation and your representative
receiving 60% to 90% (with an average of 69%) of the total compensation.
Compensation for Termination of Services
The Firms do not receive any additional compensation in connection with the termination
of the Plan's investment-related services.
Important Information
The information included
in this Notice is intended to satisfy the disclosure requirements under Section
408(b)(2) of the Employee Retirement Income Security Act of 1974, as amended (ERISA).
The Plan may incur other service charges that are not payable to The Firms. Such
charges may include legal 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 may be obtained
from the applicable service provider.
This Notice provides important information for plan fiduciaries. However, it does not modify or augment our legal responsibilities as previously provided in agreements or other materials by Stifel or any affiliate thereof.
How to Contact Us
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.