Compensation paid to Raymond James by ETP companies

Marketing and support payments

Raymond James provides a variety of marketing and other sales support services to exchange-traded product (“ETP”) companies related to their ETPs for compensation. The services provided by Raymond James to ETP companies participating in the Education and Marketing Support Program (“Program”) include, but are not limited to:

• providing detailed data reporting to the fund company
• providing fund information to financial advisors
• assisting fund companies with strategic planning and business development support
• providing opportunities to be featured in educational marketing campaigns
• providing opportunities for assisting with professional development workshops, study groups, and other educational events and conferences

Raymond James also provides distribution support for prospectuses and promotional materials relating to ETPs that participate in the Program.

Payment amounts to participate in the Program are calculated based on applicable assets under management ("AUM"), which excludes ERISA plan assets and certain fee-based retirement accounts, and may be structured as a flat dollar fee or a percentage of relevant AUM. The actual amounts that Raymond James receives will vary from one ETP company to another and certain ETP companies are subject to a minimum annual fee of up to $250,000 to participate in the Program. These payments are generally not disclosed in detail in a particular product’s prospectus or SAI, but the potential level of fees that Raymond James receives from a particular ETP company in connection with its participation in the Program will not exceed $10 million per year.  Additionally, no portion of the payments received by Raymond James is paid to or shared directly with your financial advisor or his or her respective branch office. The payments are paid directly by, or on behalf of, the ETP companies to Raymond James and are not paid directly from the assets of your ETP.

The following ETP companies have agreed to participate in the Program:

• Advisors Asset Management
• AllianceBernstein
• Allianz
• American Century Investments
• Amplify ETFs
• BlackRock iShares
• Capital Group
• Columbia Threadneedle ETFs
• Fidelity
• First Trust
• Federated Hermes
• F/m Acceleration
• Franklin Templeton
• Global X ETFs
• Harbor Capital
• Innovator
• Invesco
• J.P. Morgan
• Janus Henderson Investors
• Neuberger Berman
• Pacer Financial
• PGIM ETFs
• PIMCO
• ProShares
• State Street
• TCW
• T. Rowe Price
• VanEck
• WisdomTree
• Xtrackers by DWS

Administrative Fees 

ETP companies that do not participate in the Program pay Raymond James certain administrative fees in exchange for non-sales support related services ("Administrative Fees"), including but not limited to, services associated with onboarding ETPs onto the Raymond James platform (for e.g., operational setup, categorization, and due diligence); services related to the maintenance of the ETP on the platform for (e.g., prospectus delivery, changes to product names, tickers, CUSIPs and other identifying information, mergers and de-listings, and mutual fund to ETP conversions); and certain reporting services. The Administrative Fees are either paid per CUSIP at initial onboarding ("Onboarding Fee") with ongoing per CUSIP annual payments made thereafter ("Annual CUSIP Fee"), or as a flat annual fee ("Flat Fee"). The Administrative Fees are paid directly by, or on behalf of, the ETP companies to Raymond James and are typically not paid directly from the assets of your ETP. Additionally, no portion of these payments received by Raymond James is paid to or shared directly with your financial advisor or his or her respective branch office. The minimum amounts of the Administrative Fees are detailed below: 

• Onboarding Fee - $7,500 per CUSIP
• Annual CUSIP Fee - $2,500-$5,000 per CUSIP, depending on applicable AUM
• Flat Fee - $500,000 annually 

General promotional activities

Marketing representatives of ETP companies or their affiliated distributors, who are often referred to as “wholesalers,” work with Raymond James financial advisors to promote their ETPs. Consistent with applicable laws and regulations, these ETP companies and their wholesalers may pay for or provide training and education programs for Raymond James financial advisors and their existing and prospective clients. ETP companies may also pay for due diligence meetings, conferences, relationship building events, other occasional activities, and/or provide promotional items that are intended to result in the promotion and sale of their ETPs.

Conferences

ETP companies participate in educational conferences organized or sponsored by Raymond James to provide generalized product information and may pay Raymond James a fee to offset the cost of a conference.