Michael B Ludwig

In an investment advisory account, you will incur advisory fees which are generally assessed quarterly at the rate you agreed upon with your financial professional (based on our established fee schedule). Generally that will be a “wrap” fee that covers the applicable advisory fee, third-party manager fees, execution charges on trades, and custody and clearing services. The wrap fee does not include commissions and other charges for trades that a third-party manager directs to another broker/ dealer. In addition, it does not include underlying management fees and operating expenses for investment products and other charges described in our advisory brochure.

Because we and your financial professional are compensated based on the amount of assets in your account, we and your financial professional are incentivized to increase your assets.

During periods of lower trading activity, the advisory fee may be higher than the transaction charges you would have paid in a brokerage account. To determine whether an investment advisory account is appropriate for you, you should carefully analyze the projected costs of an investment advisory account versus a brokerage account based on factors such as expected size, volume and frequency of transactions, projected holding period and the advisory services provided by your financial professional.

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. Please make sure you understand what fees and costs you are paying.

For additional information about our fees and charges, please visit:raymondjames.com/clientfees; raymondjames.com/legal-disclosures.

When we provide you with a recommendation as a 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 about these conflicts because they can affect the recommendations and investment advice we provide you. Here are some examples to help you understand what this means.

Proprietary products – We and our affiliates serve as the investment manager for some investments and earn a management fee. Some products offered to you include fees paid to us for the use of proprietary research. Any such fees are in addition to any brokerage transaction charges or advisory fees you will incur. We therefore have a financial incentive to recommend proprietary products over third-party products.

Third-party payments – We receive payments from third parties when you invest in certain products (e.g. mutual funds). These payments represent additional compensation to us, or provide compensation for ongoing support activities we perform on behalf of third parties, such as product servicing, tax reporting, statement and trade confirmation mailings or recordkeeping. This results in a financial incentive to recommend products that provide additional compensation to us over those that pay lesser amounts or none at all. Such payments may also affect which products we make available.

Revenue sharing - The companies that sponsor, manage, and/ or promote certain investments offered by us earn revenue by charging you a fee, such as a management fee in a mutual fund. A portion of these fees may be shared with us. We use the payments in part to support activities related to servicing client accounts, to provide educational programs and technology applications to financial professionals, and to provide ongoing product support for certain investments. We have an incentive to promote the product sponsors that share the most revenues over those that share less revenues or none at all.

Principal trading – We may buy a security from you or sell you a security from our own account, predominantly with bonds and other fixed income securities. This may create incentives to act against your best interest to generate trading profits or minimize losses. When permitted in an advisory account, principal transactions require trade by trade consent.

This summary does not identify all of our conflicts of interest, or all material facts about the conflicts of interest listed. For additional information about these and other conflicts of interest, please see raymondjames.com/legal-disclosures .

Most financial professionals are compensated as a percentage of the revenue sources described below:

• Commissions, markups and markdowns earned in brokerage accounts, which vary by product.

• Ongoing fees from mutual fund and certain other product issuers.

• Advisory fees which are generally assessed quarterly at the rate you agreed upon with your financial professional (based on our established fee schedule).

• Fees related to other products and services provided to you.

The percentage of revenue that your financial professional receives will generally increase as total revenue earned from their client accounts increases. Therefore, financial professionals are incentivized to increase revenues on your and other clients’ accounts.

• Financial professionals may receive incentive compensation based on revenues earned from client accounts, assets under management, and other performance metrics such as professional competencies, designations, etc. Incentive compensation may include retention bonuses in the formof restricted stock units of Raymond James Financial, Inc., deferred compensation, paid travel for recognition trips and reimbursement of certain expenses.

• When financial professionals affiliate with us, they may receive compensation in connection with transitioning from their prior firm. This includes an upfront payment and additional potential compensation based on the revenues generated from client accounts in the first few years or on the growth in total assets they manage. This creates incentives for financial professionals to encourage you to move your assets to Raymond James and to produce greater revenues by charging higher fees and engaging in commission-generating securities transactions.

In a brokerage account, you will incur transaction charges when you buy or sell securities, including:

• Commissions;

• Markups and markdowns (similar to commissions);

• Upfront or ongoing fees that you pay to a mutual fund or other product issuer, a portion of which is paid to us in connection with your transaction; and

• Handling and processing fees on each securities transaction.

Transaction charges differ from one product to another which creates an incentive to recommend products that have higher transaction charges. You will incur greater total transaction charges when there are more trades in your account, which creates an incentive to encourage you to trade more often.

Depending upon your account and relationship, you may also incur periodic account maintenance or IRA custodial fees, as well as processing, service, and account fees upon certain events or occurrences. You will incur interest charges if you borrow on margin using a securities-based loan in any of your accounts. Certain investments, such as mutual funds, have embedded fees that are generally paid by you to the companies that sponsor, manage, and/or promote the investment.

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. Please make sure you understand what fees and costs you are paying.

For additional information about our fees and charges, please visit:raymondjames.com/clientfees; raymondjames.com/legal-disclosures.

When we provide you with a recommendation as a 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 about these conflicts because they can affect the recommendations and investment advice we provide you. Here are some examples to help you understand what this means.

Proprietary products – We and our affiliates serve as the investment manager for some investments and earn a management fee. Some products offered to you include fees paid to us for the use of proprietary research. Any such fees are in addition to any brokerage transaction charges or advisory fees you will incur. We therefore have a financial incentive to recommend proprietary products over third-party products.

Third-party payments – We receive payments from third parties when you invest in certain products (e.g. mutual funds). These payments represent additional compensation to us, or provide compensation for ongoing support activities we perform on behalf of third parties, such as product servicing, tax reporting, statement and trade confirmation mailings or recordkeeping. This results in a financial incentive to recommend products that provide additional compensation to us over those that pay lesser amounts or none at all. Such payments may also affect which products we make available.

Revenue sharing - The companies that sponsor, manage, and/ or promote certain investments offered by us earn revenue by charging you a fee, such as a management fee in a mutual fund. A portion of these fees may be shared with us. We use the payments in part to support activities related to servicing client accounts, to provide educational programs and technology applications to financial professionals, and to provide ongoing product support for certain investments. We have an incentive to promote the product sponsors that share the most revenues over those that share less revenues or none at all.

Principal trading – We may buy a security from you or sell you a security from our own account, predominantly with bonds and other fixed income securities. This may create incentives to act against your best interest to generate trading profits or minimize losses. When permitted in an advisory account, principal transactions require trade by trade consent.

This summary does not identify all of our conflicts of interest, or all material facts about the conflicts of interest listed. For additional information about these and other conflicts of interest, please see raymondjames.com/legal-disclosures .

Most financial professionals are compensated as a percentage of the revenue sources described below:

• Commissions, markups and markdowns earned in brokerage accounts, which vary by product.

• Ongoing fees from mutual fund and certain other product issuers.

• Advisory fees which are generally assessed quarterly at the rate you agreed upon with your financial professional (based on our established fee schedule).

• Fees related to other products and services provided to you.

The percentage of revenue that your financial professional receives will generally increase as total revenue earned from their client accounts increases. Therefore, financial professionals are incentivized to increase revenues on your and other clients’ accounts.

• Financial professionals may receive incentive compensation based on revenues earned from client accounts, assets under management, and other performance metrics such as professional competencies, designations, etc. Incentive compensation may include retention bonuses in the formof restricted stock units of Raymond James Financial, Inc., deferred compensation, paid travel for recognition trips and reimbursement of certain expenses.

• When financial professionals affiliate with us, they may receive compensation in connection with transitioning from their prior firm. This includes an upfront payment and additional potential compensation based on the revenues generated from client accounts in the first few years or on the growth in total assets they manage. This creates incentives for financial professionals to encourage you to move your assets to Raymond James and to produce greater revenues by charging higher fees and engaging in commission-generating securities transactions.