Peter C. Kamler

As part of your investment decision making process, it is important for you to know the fees and costs that you will incur for your brokerage or investment advisory services, including how frequently they are assessed and the conflicts of interest they create so you can carefully consider which types of accounts and services are right for you.

We typically provide transaction-specific recommendations and receive compensation on a transaction-by-transaction basis (such as commissions) every time you buy or sell an investment. The transaction-based fee you pay typically varies based on the amount invested. For example, you will pay more when there are more trades in your account and we may, therefore, have an incentive to encourage you to trade often.

For investments in stocks or ETFs, the transaction-based fee is usually charged as a separate commission or sales charge. For investments in bonds, this fee is typically included as part of the price you pay for the investment (called a mark-up or markdown). For investments in certain products such as mutual funds, annuities, and alternative investments, we receive transaction-based fees from the investment product sponsor in the form of asset-based sales charges (called sales loads). Additional costs would include, for example, both costs associated with the purchase of the security, as well as any costs that may apply to the future sale or exchange of the security, such as deferred sales or surrender charges. These fees are based on the amount invested in the product and, depending on the product, may be based on how long you hold the investment. When we receive asset-based sales loads, we have an incentive to recommend products or sponsors that include sales charges. In addition, you may also pay fees for custodial or administrative services.

For more information, please see the Client Information page of our website. For more detailed information regarding your specific situation and fees related thereto, consult with your financial professional.

Other Fees and Costs

In addition to brokerage and/or advisory fees, you may also pay fees charged by the specific investment products in which you are invested, such as mutual funds and exchange traded funds, that will reduce the value of your investments over time.

Additional Information

Although cost is an important factor that is considered when making a recommendation, it is not the only consideration and therefore our recommendations are not always the lowest cost option available. As fees and costs affect the value of your account over time, please ask your financial professional to give you personalized information on the fees and costs that you will pay. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time.

We receive compensation that typically varies depending on what securities transaction or investment strategy involving securities is being recommended. The source of our compensation may also vary, such as being paid directly by you as the investor or by a product sponsor. Because we are compensated for our recommendations there is a conflict of interest that exists between our recommendations and the varying amounts of compensation received from those recommendations. We provide these disclosures regarding conflicts to reasonably inform you as the investor so that you may use the information to evaluate the recommendations made by us.

When we provide you with a recommendation as your broker-dealer or act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the recommendations and investment advice we provide you.

Examples of Ways We Make Money and Conflicts of Interest:

• Third-Party Payments: We receive compensation from third parties derived from the sale of securities or other investment products held by you, including asset-based sales charges or service fees on mutual funds, annuities, ETFs, alternative investments, and other investments. This compensation includes ongoing distribution charges such as 12b-1 fees or trail payments which an investment product charges you and then pays to us. We may also receive fees from investment products and/or their sponsors for administrative or marketing services we provide in relation to your investments. These compensation arrangements give us an incentive to recommend certain products over other products for which we receive less compensation. When we recommend a particular fund, we will provide more specific detail about compensation arrangements associated with the specific fund family.

• Revenue Sharing: We may receive compensation from revenue sharing agreements derived from the sale of mutual funds, direct-participation programs such as non-traded REITs, business development companies and other investments. These revenue-sharing fees are paid by product sponsors directly to us for marketing support, due diligence, and training. Therefore, these revenue-sharing arrangements give us an incentive to recommend certain products over other products for which we receive less compensation.

• Principal Trading: In brokerage accounts, we sometimes buy bonds from you or sell bonds to you which are considered principal trades. In these instances, we will receive a mark-up or markdown which is the difference between a bond’s price and the price (higher or lower) at which we buy or sell it. This creates an incentive for us to either buy the bond from you at the lowest price possible or sell the bond to you at the highest price possible to maximize our profit.

If our financial professionals have conflicts of interest beyond those disclosed in this relationship summary, they will disclose, where appropriate, any additional material conflicts of interest not later than the time of a recommendation, and any such disclosure will be made orally. Additional information about our conflicts of interest can be found on the Client Information page of our website.

We have agreements in place with our financial professionals, who are independent contractors of the firm, which determine what and how we pay them. Our financial professionals who provide brokerage services will receive a portion of the commissions received from your trades, while those providing advisory services will receive a portion of the advisory fees you pay us. We also pay our financial professionals different rates of compensation based on production, including payments based on the amount of assets they service or the types of products they sell. Although your financial professionals must recommend investment products or manage your account in your best interest, these forms of compensation, such as brokerage commissions, advisory fees and other production-related compensation, create an incentive for them to recommend certain products, encourage you to trade more frequently or increase your investment account size. We do not have sales contests, sales quotas, bonuses, and/or non-cash compensation that are based on the sale of specific securities or specific types of securities.