Compensation and Reimbursement of Expenses to International Assets Advisory, LLC and Representatives
International Assets Advisory, LLC (“IAA”), and their representatives receive revenue on the products and services you purchase from several sources. These sources include fees and charges you pay and other arrangements we have in place with affiliated and non-affiliated entities including sales charges; commissions; periodic fees; periodic expenses paid from product assets such as 12b-1 fees from mutual funds and the funds available in variable annuities; and a portion of the organization and offering fees and expenses for real estate investment trusts (“REITs”), limited partnerships and other nonpublic securities offerings.
IAA receives compensation from certain mutual funds and variable product sponsors available to you through our representatives. For commission-based products, these payments include:
• sales charges (sometimes called loads); and
• trailing commissions (including service fees known as 12b-1 payments).
We also receive additional payments called revenue sharing payments and/or marketing allowances from certain product sponsors under special agreements with those firms. Additional details concerning these arrangements are set forth below. We also maintain revenue and marketing allowance payment programs involving certain REITs.
Representatives of product sponsors, often referred to as “wholesalers,” work with IAA and its representatives to promote their products. These product sponsors are generally granted access to our representatives to promote and educate IAA’s representatives of their products. Consistent with rules set out by the Financial Industry Regulatory Authority (“FINRA”), certain of these wholesalers and/or their firms, when consistent with their internal policies, pay IAA for training or education of our representatives. Some product sponsors also make payments to IAA to promote the marketing of their products to clients which payments include covering in whole or in part the cost of seminars for clients and potential clients. Some product sponsors, when consistent with their internal policies, also invite representatives to due diligence or continuing education meetings regarding their products. From time to time IAA allows its representatives to attend off-site training sessions that are sponsored or co-sponsored by these product sponsors. IAA prohibits the promotion of any product, including those issued by fund families, insurance carriers, or sponsors, over another based solely on additional payments, higher compensation structure or other considerations received from the sale or marketing of products. Representatives are required to make recommendations to clients based on the clients’ needs and objectives; however, receipt of such reimbursements also creates a conflict of interest in the form of an incentive by your representative to recommend products that provide such payments. We encourage you to talk with your representative about any fees or compensation they receive from the sale of investment products.
IAA has partnered with certain mutual fund, variable annuity and retirement plan providers providing them greater access to our representatives to provide training, education presentations and product information. The purpose is to identify creative ways to help these companies increase field visibility, identify meaningful representative networking opportunities and present timely products. In return for these increased services, these sponsor firms compensate IAA in the form of revenue sharing payments. In addition to the customary sales commissions paid in connection with sales of mutual funds, variable annuities, and money market funds, these sponsor firms make payments to IAA to participate in the Partner program.
Non-Publicly Traded Products
IAA offers several non-publicly traded products, including, but not limited to, REITs, limited partnerships, 1031 exchange programs, direct participation programs, oil and gas programs, and private equity funds. IAA conducts or causes to be conducted a due diligence analysis of these products prior to making them available to the public through its representatives. Such due diligence is not a guarantee or assurance the products will not lose their value and you should read any offering document or prospectus for such products carefully as they describe the risk associated with such investments. In addition to receiving commissions on the sale of these products, IAA receives due diligence and/or marketing allowance payments from certain sponsors.
In addition, in some cases IAA will be reimbursed by the product sponsors for expenses incurred for various promotional activities including, but not limited to, sales meetings, conferences, and seminars held in the ordinary course of business.
Due Diligence and Product Administration Expenses
Consistent with prudent product approval and due diligence practices IAA will, in some cases, require an independent third party to conduct a review of a product sponsor, investment company, or their products or services prior to making the product or service available for solicitation to the general public by representatives.
Revenue Sharing and Referral Arrangements with our Clearing Firm
IAA has a clearing and custody agreement with RBC Correspondent Services (“RBC”). IAA receives various forms of revenue from RBC based upon client activity, as well as the number of assets custodied with the firm. In general, IAA shares with the clearing firm the expense of trade execution and account servicing. The revenue sources include, but are not limited to, a percentage or portion of fees and transaction charges collected by the clearing firms and shared with IAA, which typically include ticket charges, margin interest charges, inactivity fees, and other fees set forth in the Schedule of Client Fees and Charges and money market fund 12b-1 trails.
Fixed Insurance and Annuities
IAA affiliates include licensed insurance agencies that receive commissions in connection with the sale of fixed insurance and annuity products by IAA representatives who are licensed to sell fixed insurance and annuity products. IAA, in addition to receiving commissions on the sale of these insurance products, receives payments from certain insurance sponsors for supervision, training, marketing, and distribution support. This creates a conflict of interest in that the marketing, educational, and distribution activities paid for with revenue sharing could lead our representatives/insurance agents to consider insurance products that make revenue sharing payments to IAA – as compared to insurance sponsors that do not make such payments – when recommending insurance products to their clients.