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 an insurance company's recordkeeping platform investing in a group annuity contract, group funding agreement or other insurance company issued contract (hereinafter, collectively, a "Group Annuity"). 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, and 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 provides 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 a registered broker-dealer, the Firms receive payments from the issuer and/or
an affiliate of the issuer (the "Issuer") of the Plan's Group Annuity contract as
indirect compensation for the investment-related services provided on behalf of
the Plan. Such indirect compensation includes commissions payable from the Issuer.
Commissions may be deposit-based (i.e., based on new purchase amounts under the
Group Annuity) and/or asset-based (i.e., based on the total investment under the
Group Annuity), and they may be charged on an ongoing basis or for only a fixed
period. These commissions are payments made from the Issuer's assets, and they do
not reduce the amount invested by the Plan or the Plan's investment earnings. The
amount of any commission payable from the Issuer of the Group Annuity to the Firms
is described in the proposal or the contract or service agreement from the Group
Annuity.
In addition to commissions, the Issuer may also pay the Firms' expenses, or provide non-cash items and services, to facilitate training and educational meetings for the Firms' financial advisors, which do not depend on the amount of the Plan's investment under the Group Annuity.
Compensation Paid Among Related Parties
Stifel receives indirect compensation from the Plan. These payments are
not shared with any entities affiliated with Stifel or with any other entities.
Stifel Independent Advisors receives compensation from the Plan. These payments paid 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
This Notice describes certain types of compensation payable directly or indirectly
to The Firms in connection with the investment-related services provided on behalf
of your Plan. 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. In addition, please refer to your Group Annuity recordkeeping platform's
proposal, service agreement, and/or contract.
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. 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.
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.