Mutual Funds Disclosure

Introduction

A mutual fund is a collection of securities owned by a group of investors and managed by a professional investment adviser. A mutual fund pools investors' money to invest in a portfolio of stocks, bonds, money markets or a combination of these asset classes. Because the fund typically holds many different types of securities within a particular asset class, it offers greater diversification than you could achieve on your own. Most mutual funds aim at a particular objective—whether immediate income, income and growth, or long-term growth.

Revenue Allowance for Marketing, Education & Training

Some mutual fund families pay Park Avenue Securities (PAS), Guardian's retail broker/dealer subsidiary, a revenue allowance for marketing, education, and/or training in support of our Financial Representatives. Since this information may be an important consideration in your decision to purchase a particular mutual fund product, you should read more about these payments in each mutual fund prospectus and statement of additional information. PAS is paid a flat dollar amount on a quarterly basis that is not tied to any assets placed with the mutual fund company for providing marketing and educational opportunities and a level of access to PAS Financial Representatives. Please see the below chart for more detailed information. Accepting this type of compensation presents a conflict of interest because PAS has an incentive to recommend this investment company based on the compensation it receives, rather than client needs.

It is important to note that PAS Financial Representatives do not receive any portion of these fees, which are separate from and in addition to other fees and charges applicable to each product.

Representatives of mutual fund families, subject to the discretion of Branch Office Managers, may be provided access to our branch offices and Financial Representatives for educational, marketing and other promotional efforts.

Although all fund families are provided with such access, some fund families devote more staff and resources to these activities and therefore may have enhanced opportunities to promote their funds to our Financial Representatives. This fact could, in turn, lead our Financial Representatives to focus on those funds when recommending mutual fund investments to our clients instead of on funds from those fund families that do not commit similar resources to education, marketing and other promotional efforts. 

A listing of mutual fund families currently participating in this type of support is set forth below:

Other Expense Reimbursements: PAS and/or your Financial Representative may be reimbursed by mutual fund companies or their affiliates or other service providers for the expenses PAS and/or your Financial Representative may incur for various sales meetings, seminars, and conferences held in the normal course of business or for other services performed. Although mutual fund companies independently decide what they will spend on these activities, we are aware that some fund companies allocate their promotional budgets based upon prior sales and asset levels and that they work with our branch offices or Financial Advisors to plan promotional and educational activities on the basis of such budgets. We do not control mutual fund companies' determinations of how to allocate their promotional budgets or their spending decisions in this regard. Note that PAS policies establish procedures intended to ensure that the acceptance of the type of compensation described in this paragraph is carried out in conformity with applicable industry regulations. In particular, all proposed compensation of this type must be fully disclosed to, and approved in writing by, the PAS Compliance Department prior to acceptance.

FINRA rules prohibit Financial Representatives from receiving cash or non-cash compensation, unless prior approval is obtained from the Financial Representative’s employing broker/dealer. Based upon this rule, no Financial Representative may accept cash or non-cash compensation from any product sponsor, unless express prior written approval is obtained from the PAS Compliance Department. 

Understanding Mutual Fund Share Classes