We recommend the brokerage and custodial services of Mutual Securities Corporation, a registered broker-dealer and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. We believe that Mutual Securities Corporation provides quality execution services for you at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by Mutual Securities Corporation, including the value of research provided, the firm's reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. In recognition of the value of research services and additional brokerage products and services Mutual Securities Corporation provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere.
We also make investment options available to you through Fidelity Brokerage Services for no load or net asset value purchases on mutual funds. Stocks and other securities are available through Fidelity for their minimum charge, which pays no compensation or commission to our firm. We also use Mutual Securities Corporation for commission accounts. For investment management clients, Fidelity Brokerage Services is recommended in order to reduce the possible conflict of interest posed by the presence of commission income.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research.
Persons providing investment advice on behalf of our firm who are registered representatives of Mutual Securities Corporation will recommend Mutual Securities Corporation to you for brokerage services. These individuals are subject to applicable rules that restrict them from conducting securities transactions away from Mutual Securities Corporation unless Mutual Securities Corporation provides the representative with written authorization to do so. Therefore, these individuals are generally limited to conducting securities transactions through Mutual Securities Corporation. It may be the case that Mutual Securities Corporation charges higher transactions costs and/or custodial fees than another broker charges for the same types of services. If transactions are executed though Mutual Securities Corporation, these individuals (in their separate capacities as registered representatives of Mutual Securities Corporation may earn commission-based compensation as result of placing the recommended securities transactions through Mutual Securities Corporation. This practice presents a conflict of interest because these registered representatives have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on your needs. You may utilize the broker-dealer of your choice and have no obligation to purchase or sell securities through such broker as, we recommend. However, if you do not use Mutual Securities Corporation, we may not be able to accept your account. Please see the “Fees and Compensation” section in this brochure for more information on the compensation received by registered representatives who are affiliated with our firm.
In limited circumstances, and at our discretion, some clients may instruct our firm to use one or more particular brokers for the transactions in their accounts. If you choose to direct our firm to use a particular broker, you should understand that this might prevent if adviser aggregates] our firm from aggregating trades with other client accounts. This practice may also prevent our firm from obtaining favorable net price and execution. Thus, when directing brokerage business, you should consider whether the commission expenses, execution, clearance, and settlement capabilities that you will obtain through your broker are adequately favorable in comparison to those that we would otherwise obtain for you.
We may combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion regarding factual and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment.