Business Continuity & Other Disclosures
Important Legal Information
Auction Rate Securities Payments Disclosure
Annuity Fees and Revenue Sharing Disclosure
Business Continuity Disclosure
Business Continuity Planning—Pandemic Statement of Preparation
Disclosure Statement
Estimated Annual Income And Estimated Yield
Estimated Annual Income And Estimated Yield (Spanish)
Event Sponsorship Fees Disclosure
Execution Quality Disclosure, SEC Rule 605
Extended Hours Trading Risk Disclosure
Mutual Fund, Money Fund, and FDIC-Insured Bank Product, Disclosures—Charges, Breakpoint Discounts, Fees, and Revenue Sharing
Order Routing Disclosure, SEC Rule 606
National Instrument 24-101 Trading Matching and Settlement
Nonbank Custodian Statement Message
Prohibition against Internet Gambling
Unit Investment Trust (UIT) Payments Disclosure

Important Legal Information - Please read the disclaimer before proceeding

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  • This site has been designed for informational purposes only and does not constitute an offer to sell nor a solicitation of an offer to buy any security that may be referenced on the site. Such offers can only be made where lawful under applicable law. The services and information provided through this site are for investment professional use only and not intended for personal individual use. Pershing LLC and its affiliates do not intend to provide investment advice through this site and do not represent that the securities or services discussed are suitable for any investor. Pershing and its affiliates do not, and this site does not intend to, render tax or legal advice.
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Auction Rate Securities Payments Disclosure
Pershing may receive payments from the distribution agent for trades in municipal auction rate securities and closed end fund/preferred auction rate securities executed by Pershing upon your financial organization's instruction. These payments are not charged to or paid by you. Additional information regarding such payments is available at www.pershing.com/ARS_fees.html.

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Annuity Fees and Revenue Sharing Disclosure
Pershing may receive servicing fees from certain insurance companies that participate in Pershing's annuity program. Participation by your financial organization in this program is optional. These fees may be considered revenue sharing and are a source of revenue for Pershing.

Pershing also receives operational reimbursement fees from certain insurance companies. A flat fee per holding is paid to Pershing for the services it provides, which may include, but is not limited to posting, accounting reconciliation, and client statement preparation and mailing. These fees are a source of revenue for Pershing. For additional details regarding processing annuities and a listing of annuities that pay Pershing revenue sharing and processing fees, please refer to www.pershing.com/annuity_fees.htm.

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Business Continuity Disclosure
DISCLOSURE REQUIRED BY FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) 4370
To address interruptions to our normal course of business, Pershing maintains a business continuity plan, which includes geographically dispersed data centers and alternate processing facilities. The plan is reviewed annually and updated as necessary.

The plan outlines the actions Pershing will take in the event of a building, city, or regional incident, including:

  • Continuous processing support by personnel located in unaffected facilities
  • Relocating technology or operational personnel to alternate regional facilites
  • Switching technology data processing to an alternate regional data center
All Pershing operational facilities are equipped for resumption of business and are tested. Regarding all circumstances within our control, Pershing's recovery time objective for business resumption, including those involving a relocation of personnel or technology, is four (4) hours, depending upon the availability of external resources.

In the event that your financial organization experiences a significant business interruption, you may contact Pershing directly to process limited trade-related transactions, cash disbursements, and security transfers. Instructions to Pershing must be in writing and transmitted via facsimile at (201) 413-5368 or by postal service as follows:

Pershing LLC
P.O. Box 2065
Jersey City, New Jersey 07303-2065

For additional information about how to request funds and securities when your financial organization cannot be contacted due to a significant business interruption, please visit the Customer Support section or call (201) 413-3635 for recorded instructions.

If you cannot access the instructions from the web site or the previously noted telephone number, you may call (213) 624-6100, extension 500, an alternate Pershing number for recorded instructions.

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Business Continuity Planning—Pandemic Statement of Preparation
Pershing has developed a Statement of Preparation to address the possibility of a pandemic outbreak and provide you with an overview of our plans for mitigating the potential impact.

If such a situation occurs, we are confident that we are well positioned to maintain critical functions in support of your business.

Please visit the Pandemic Statement of Preparation section of this website for complete information regarding our pandemic business continuity plans.

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Estimated Annual Income And Estimated Yield
The following disclosure pertains to estimated annual income (EAI) and estimated current yield (ECY) figures displayed on Pershing LLC's brokerage account statements.

The EAI and ECY figures are estimates and for informational purposes only. These figures are not considered to be a forecast or guarantee of future results. These figures are computed using information from providers believed to be reliable, however, no assurance can be made as to the accuracy. Since interest and dividend rates are subject to change at any time, and may be affected by current and future economic, political, and business conditions, they should not be relied on for making investment, trading, or tax decisions. These figures assume that the position quantities, interest and dividend rates, and prices remain constant. A capital gain or return of principal may be included in the figures for certain securities, thereby overstating them.

The EAI figure for U.S. government, corporate, and municipal securities is computed by multiplying the coupon rate by the quantity of the security and then dividing that figure by 100. The resulting figure is reflected on the brokerage account statement in the EAI field.

The EAI for equity, mutual fund, unit investment trust and exchange traded fund securities is computed using either a historical methodology (HM) or projected methodology (PM), depending on the information from the issuer. The PM annualizes the latest regular cash dividend. The HM accumulates the regular cash dividends over the past twelve months. If there is less than one year of dividend history, the accumulated dividends are annualized. The EAI for preferred securities is computed using the PM. The HM or PM figure, whichever is calculated, is then multiplied by the quantity of the security and the resulting figure is reflected on the brokerage account statement in the EAI field.

The following are important caveats to the HM figure and PM figure.

  • The figure is denominated in the same currency as the dividend announcement.
  • The figure does not contemplate special or extra dividends.
  • When a security pays its first dividend with no specificity as to dividend frequency, the initial dividend will be the reported figure.
  • If a security announces a stock split and does not announce a new dividend rate, the figure will be adjusted on the ex-distribution/dividend date.
  • For a called security, the figure will remain unchanged until the payment date, at which point it will revert to zero.
  • The figure for Canadian securities is calculated the same way as for U.S. securities.
  • The figure for mutual funds only includes dividends treated as income.
  • The figure will be zero under the following scenarios: a security that has only paid capital gains during the preceding year; a security that has only had stock splits, stock (not cash) dividends, or reverse stock splits during the preceding year; a security other than an open end mutual fund (excluding a money market fund), ADR preferred, or exchange traded fund which rescinds or omits a dividend payment; and a security from an issuer which is in arrears and uncertain about its ability to make a dividend payment.
The ECY figure is computed by dividing the EAI figure by the current market price of the security, which may be higher or lower than the purchase price, and then the figure is multiplied by 100. The resulting figure is reflected on the brokerage account statement in the ECY field. With specific regard to a fixed income security, the initial purchase confirmation oftentimes reflects yield to maturity, yield to call, and/or yield to worst figures which are more relevant figures from the point of purchase.

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Estimated Annual Income And Estimated Yield (Spanish)
La siguiente declaración está relacionada con las cifras correspondientes a los ingresos anuales estimados (EAI, por sus siglas en inglés) y al rédito actual estimado (ECY) presentadas en los estados de cuenta de la cuenta de corretaje de Pershing LLC.

Las cifras correspondientes a los ingresos anuales estimados (EAI) y al rédito actual estimado (ECY) son estimativas y se proporcionan únicamente con fines informativos. No se considera que estas cifras constituyan una previsión o garantía de los resultados futuros. Estas cifras se calculan utilizando información proveniente de proveedores que se consideran confiables; no obstante, no puede brindarse seguridad con respecto a su exactitud. Dado que las tasas de interés y de dividendos están sujetas a cambio en cualquier momento, y pueden verse afectadas por las condiciones económica, política y empresarial, tanto actuales como futuras, no se debería confiar en dichas tasas para tomar decisiones en materia de inversiones, compraventa o de carácter tributario. Estas cifras suponen que las cantidades de la posición, las tasas de interés y de dividendos, y los precios permanecen constantes. En el caso de ciertos títulos, en las cifras se puede incluir una ganancia de capital o rendimiento del capital, con lo cual dichas cifras estarían sobreestimadas.

La cifra de ingresos anuales estimados (EAI) correspondiente a títulos del gobierno de EE. UU., títulos corporativos y títulos municipales se calcula multiplicando la tase de cupón por la cantidad de títulos y luego dividiendo esa cifra por 100. La cifra que se obtiene como resultado se refleja en el estado de cuenta de la cuenta de corretaje en el campo correspondiente a los ingresos anuales estimados (EAI).

Los ingresos anuales estimados (EAI) correspondientes a títulos accionarios, títulos de fondos mutuos, títulos de fondos mutuos de inversiones (unit investment trust) y títulos de fondos comercializados en bolsa se calculan utilizando ya sea una metodología histórica (HM, por sus siglas en inglés) o una metodología proyectada (PM, por sus siglas en inglés), dependiendo de la información proveniente del emisor. La metodología proyectada (PM) anualiza el último dividendo en efectivo regular. La metodología histórica (HM) acumula los dividendos en efectivo regulares de los últimos 12 meses. Si el historial de dividendos es menor a un año, los dividendos acumulados se anualizan. Los ingresos anuales estimados (EAI) correspondientes a los títulos preferentes se calculan utilizando la metodología proyectada (PM). La cifra correspondiente a la metodología histórica (HM) o a la metodología proyectada (PM), cualquiera que sea calculada, luego se multiplica por la cantidad del título, y la cifra que se obtiene como resultado se refleja en el estado de cuenta de la cuenta de corretaje en el campo correspondiente a los ingresos anuales estimados (EAI).

Las siguientes son advertencias importantes para calcular la cifra mediante la metodología histórica (HM) y la metodología proyectada (PM).

  • La cifra está denominada en la misma moneda que el anuncio de dividendo.
  • La cifra no contempla dividendos especiales o extras.
  • Cuando un título paga su primer dividendo sin especificar la frecuencia del dividendo, el dividendo inicial será la cifra informada.
  • Si un título anuncia una división de acciones y no anuncia una nueva tasa de dividendo, la cifra se ajustará en la fecha sin distribución (ex-distribution) o sin dividendo (ex-dividend).
  • En el caso de un título rescatado, la cifra permanecerá sin cambio ?hasta la fecha de pago, momento en el cual se revertirá a cero.
  • La cifra para los títulos canadienses se calcula de la misma forma que para los títulos estadounidenses.
  • La cifra para los fondos mutuos solamente incluye dividendos tratados como ingresos.
  • La cifra será cero en las siguientes situaciones hipotéticas: un título que solamente ha pagado ganancias de capital durante el año anterior; un título que solamente ha tenido división de acciones, dividendos de acciones (no dividendos en efectivo) o divisiones inversas de acciones, durante el año anterior; un título que no sea de un fondo mutuo abierto (sin incluir un fondo de mercado monetario), un fondo de recibos de depósito americanos (ADR, por sus siglas en inglés) preferentes o un fondo comercializado en bolsa, que rescinda u omita un pago de dividendo; y un título proveniente de un emisor que esté en mora y no tenga certeza acerca de su capacidad de efectuar un pago de dividendo.
La cifra correspondiente al rédito actual estimado (ECY) se calcula dividiendo la cifra de los ingresos anuales estimados (EAI) por el precio actual de mercado del título, el cual puede ser mayor o menor que el precio de compra, y luego la cifra se multiplica por 100. La cifra que se obtiene como resultado se refleja en el estado de cuenta de la cuenta de corretaje en el campo correspondiente al rédito actual estimado (ECY). Específicamente con respecto a un título de ingresos fijos, la confirmación de compra inicial a menudo refleja el rédito hasta el vencimiento, el rédito hasta el rescate y/o el rédito con relación a las peores cifras, que constituyen las cifras más importantes desde el punto de vista de la compra.

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Event Sponsorship Fees Disclosure
Mutual fund companies, annuity companies, exchange traded fund (ETF) providers, money market providers, and other solution providers offer marketing support in the form of payments to Pershing (or third parties at Pershing's direction) in connection with educational conferences, events, seminars, and workshops for broker-dealers or investment professionals. These payments may be for the expenses of educational materials or other conference-related expenses. For a listing of companies that pay contributions to Pershing for events, please refer to www.pershing.com/event.

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Extended Hours Trading Risk Disclosure
You should consider the following points before engaging in extended hours trading. "Extended hours trading" means trading outside of "regular trading hours." "Regular trading hours" generally means the time between 9:30 a.m. and 4:00 p.m. (ET).

  • Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities, and as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular trading hours. As a result, your order may only be partially executed, or not at all.
  • Risk of Higher Volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular trading hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price when engaging in extended hours trading than you would during regular trading hours.
  • Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular trading hours, or upon the opening the next morning. As a result, you may receive an inferior price when engaging in extended hours trading than you would during regular trading hours.
  • Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours trading system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended hours trading system than you would in another extended hours trading system.
  • Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular trading hours. Similarly, important financial information is frequently announced outside of regular trading hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.
  • Risk of Wider Spreads. The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.
  • Risk of Higher Volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended-hours trading than in regular market hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price in extended-hours trading than you would during regular market hours.
  • Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market hours. In extended-hours trading, these announcements may occur during trading and, if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.
  • Risk of Wider Spreads. The spread refers to the difference in price for which you can buy and sell a security. Lower liquidity and higher volatility in extended-hours trading may result in wider than normal spreads for a particular security.

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Mutual Fund, Money Fund and FDIC-Insured Bank Product Disclosures
CHARGES, BREAKPOINT DISCOUNTS, FEES, AND REVENUE SHARING
Before investing in mutual funds, it is important that you understand the sales charges, expenses, and management fees that you will be charged, as well as the breakpoint discounts to which you may be entitled. Understanding these charges and breakpoint discounts will assist you in identifying the best investment for your particular needs and may help you to reduce the cost of your investment.

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This section will give you general background information about these charges and discounts; however, sales charges, expenses, management fees, and breakpoint discounts vary from mutual fund to mutual fund. Therefore, you should discuss these matters with your investment professional and review each mutual fund's prospectus and statement of additional information (which are available from your investment professional) to obtain the specific information regarding the charges and breakpoint discounts associated with a particular mutual fund.

Mutual Fund Sales Charges
Investors who purchase mutual funds must make certain choices, including which funds to purchase and which share class is most advantageous in light of their specific investing needs. Each mutual fund has a specified investment strategy. You should consider whether the mutual fund's investment strategy is compatible with your investment objectives. Additionally, many mutual funds offer different share classes. Although each share class represents a similar interest in the mutual fund's portfolio, the mutual fund will charge you different fees and expenses depending upon your choice of share class. As a general rule, Class A shares carry a "front-end" sales charge or "load" that is deducted from your investment at the time you buy the fund shares. This sales charge is a percentage of your total purchase.

As explained below, many mutual funds offer volume discounts to the front-end sales charge assessed on Class A shares at certain predetermined levels of investment, which are called "breakpoint discounts." In contrast, Class B and C shares usually do not carry any front-end sales charges. Instead, investors who purchase Class B or C shares pay asset-based sales charges, which may be higher or lower than the charges associated with Class A shares. Investors who purchase Class B or C shares may also be required to pay a sales charge known as a contingent deferred sales charge when they sell their shares, depending upon the rules of the particular mutual fund. This is known as a "back-end" sales charge or "load."

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Mutual Fund Breakpoint Discounts
Most mutual funds offer investors a variety of ways to qualify for breakpoint discounts on the sales charge associated with the purchase of Class A shares. In general, most mutual funds provide breakpoint discounts to investors who make large purchases at one time. The extent of the discount depends upon the size of the purchase.

Generally, as the amount of the purchase increases, the percentage used to determine the sales load decreases. The entire sales charge may be waived for investors who make very large purchases of Class A shares. Mutual fund prospectuses contain tables that illustrate the available breakpoint discounts and the investment levels at which breakpoint discounts apply. Additionally, most mutual funds allow investors to qualify for breakpoint discounts based upon current holdings from prior purchases through Rights of Accumulation (ROA) and from future purchases based upon Letters of Intent (LOI). Mutual funds have different rules regarding the availability of ROAs and LOIs. Therefore, you should discuss these matters with your investment professional and review the mutual fund's prospectus and statement of additional information to determine the specific terms upon which a mutual fund offers ROAs or LOIs.

Rights of Accumulation-Many mutual funds allow investors to count the value of previous purchases of the same fund, or another fund within the same fund family, with the value of the current purchase to qualify for breakpoint discounts. Moreover, mutual funds may allow investors to count existing holdings in multiple accounts, such as individual retirement accounts (IRAs) or accounts at other financial organizations to qualify for breakpoint discounts. Therefore, if you have accounts at other financial organizations and wish to take advantage of the balances in these accounts to qualify for a breakpoint discount, you must advise your investment professional about those balances. You may need to provide documentation if you wish to rely upon balances in accounts at another firm.

In addition, many mutual funds allow investors to count the value of holdings in accounts of certain related parties, such as spouses or children, to qualify for breakpoint discounts. Each mutual fund has different rules that govern when relatives may rely upon each other's holdings to qualify for breakpoint discounts. You should consult with your investment professional and review the mutual fund's prospectus and statement of additional information to determine what these rules are for the fund family in which you are investing. If you wish to rely upon the holdings of related parties to qualify for a breakpoint discount, you should advise your investment professional about these accounts. You may need to provide documentation to your investment professional if you wish to rely upon balances in accounts at another firm. Mutual funds also follow different rules to determine the value of existing holdings. Some funds use the current net asset value (NAV) of existing investments in determining whether an investor qualifies for a breakpoint discount. However, a small number of funds use the historical cost, which is the cost of the initial purchase, to determine eligibility for breakpoint discounts. If the mutual fund uses historical costs, you may need to provide account records, such as confirmation statements or monthly statements, to qualify for a breakpoint discount based upon previous purchases. You should consult with your investment professional and review the mutual fund's prospectus and statement of additional information to determine whether the mutual fund uses NAV or historical costs to determine breakpoint eligibility.

Letters of Intent-Most mutual funds allow investors to qualify for breakpoint discounts by signing a LOI, which commits the investor to purchasing a specified amount of Class A shares within a defined period of time, usually 13 months. For instance, if an investor plans to purchase $50,000 worth of Class A shares over a period of 13 months, but each individual purchase would not qualify for a breakpoint discount, the investor could sign an LOI at the time of the first purchase and receive the breakpoint discount associated with a $50,000 investment on the first and all subsequent purchases. Additionally, some funds offer retroactive LOIs that allow investors to rely upon purchases in the recent past to qualify for a breakpoint discount. However, if an investor fails to invest the amount required by the LOI, the fund is entitled to retroactively deduct the correct sales charges based upon the amount that the investor actually invested. If you intend to make several purchases within a 13-month period, you should consult your investment professional and the mutual fund prospectus to determine if it would be beneficial for you to sign an LOI. As you can see, understanding the availability of breakpoint discounts is important because it may allow you to purchase Class A shares at a lower price. The availability of breakpoint discounts may save you money and may also affect your decision regarding the appropriate share class in which to invest. Therefore, you should discuss the availability of breakpoint discounts with your investment professional and carefully review the mutual fund prospectus and its statement of additional information when choosing among the share classes offered by a mutual fund. If you wish to learn more about mutual fund share classes or mutual fund breakpoints, you can also review the investor alerts that are available on the Financial Industry Regulatory Authority (FINRA) web site.

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Mutual Fund Fees and Revenue Sharing
Pershing may receive servicing fees from mutual funds that participate in Pershing's mutual fund no-transaction-fee program (FundVest®) in lieu of clearance charges to your financial organization. Participation by your financial organization in this program is optional and your financial organization may share with Pershing in such fees. These fees may be considered revenue sharing and are a significant source of revenue for Pershing and may be a significant source of revenue for your financial organization. These fees are paid in accordance with an asset-based formula.

Pershing also receives operational reimbursements from mutual funds in the form of networking or omnibus processing fees. These reimbursements are based either on a flat fee per holding or a percentage of assets and are remitted to Pershing for its work on behalf of the funds. This work may include, but is not limited to, subaccounting services, dividend calculation and posting, accounting, reconciliation, client confirmation and statement preparation and mailing, and tax statement preparation and mailing. These fees are a significant source of revenue for Pershing. For additional details about Pershing's mutual fund no-transaction-fee program, or a listing of funds that pay Pershing networking or omnibus fees, please refer to www.pershing.com/mutual_fund.htm.

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Money Fund and FDIC-Insured Bank Product Fees and Revenue Sharing
Money fund processing and revenue sharing fees are significant sources of revenue for Pershing and may be significant sources of revenue for your financial organization. Pershing receives fees from money fund providers for making available money market funds or FDIC-insured bank deposit programs, which you have selected through your financial organization. These fees are paid in accordance with an asset-based formula. Your financial organization may share in these fees. A portion of Pershing's fees is applied against costs associated with providing services on behalf of the funds, which may include maintaining cash sweep systems, sub-accounting services, dividend calculation and posting, accounting, reconciliation, client statement preparation and mailing, tax statement preparation and mailing, marketing and distribution related support, and other services.

Pershing receives processing fees from certain money fund providers, which may be associated with your financial organization. These fees reimburse Pershing for operational services it performs on behalf of the funds, which may include maintaining cash sweep systems, subaccounting services, dividend calculation and posting, accounting, reconciliation, client statement preparation and mailing, tax statement preparation and mailing, or other services. For a listing of money funds that pay Pershing revenue sharing and processing fees, please refer to www.pershing.com/money_fund.htm.

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Order Routing Disclosure
SEC Rule 606

Pershing has provided the data concerning the routing of order flow (the "Data") on the order routing disclosure web site. Although Pershing has used commercially reasonable efforts to provide accurate data, the data is provided to you on an "as is" basis.

If you would like to read this information, visit the order routing disclosure site (www.orderroutingdisclosure.com) and enter Pershing LLC when prompted for the broker-dealer's full name.

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Prohibition against Unlawful Internet Gambling
In accordance with the Unlawful Internet Gambling Enforcement Act of 2006, transactions associated with unlawful internet gambling are prohibited. Specifically, the Act "prohibits any person engaged in the business of betting or wagering from knowingly accepting payments in connection with the participation of another person in unlawful internet gambling." You must not initiate or receive wire transfers, checks, drafts or other debit/credit transactions that are restricted by the Act. For more information, please refer to: www.federalreserve.gov/newsevents/press/bcreg/20081112b.htm.

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Unit Investment Trust (UIT) Payments Disclosure
When Pershing acts upon the instruction of your financial organization to execute the purchase of a UIT, Pershing may receive a payment based on the volume of sales processed by Pershing. Your financial organization may receive a concession for the sale of the UIT to you. Such payments are disclosed in the applicable trust prospectus. Additional information regarding such payment and a list of sponsors are available at www.pershing.com/UIT_fees.html.

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