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 .

RAYMOND JAMES & ASSOCIATES

Coral Gables, FL 33134

Laura Steckler

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