Disclaimers and Privacy Statements
Copyright 2020 Larson Wealth Partners. All Rights Reserved
Securities offered through Larson Financial Securities, LLC, member FINRA/SIPC/MSRB. Advisory Services offered through Larson Wealth Partners, LLC, a Registered Investment Advisory firm. Larson Financial Securities and Larson Wealth Partners are affiliated. Larson Wealth Partners is doing business as Counsel Wealth Management.
The registered representatives associated with this site may only discuss and/or transact securities business with residents of the following states: AZ, CA, CO, FL, IA, MN, MO, NE, NM, TN, RI, WI, GA, HI, IL, IN, KS, KY, MA, MI, MT, NV, NY, NC, ND, OH, OK, SD, TX, UT, WA, WY
We take protecting your data and privacy very seriously. As of January 1, 2020 the California Consumer Privacy Act (CCPA) suggests the following link as an extra measure to safeguard your data: Do not sell my personal information.
Counsel Wealth Management - Customer Relationship Summary
Regulation Best Interest Disclosure
This guide summarizes important information concerning the scope and terms of the account services offered through Larson Financial Securities, LLC and details the material conflicts of interest that arise through our delivery of our services to you. We encourage you to review this information carefully, along with any applicable account agreement(s) and disclosure documentation you may receive from us or your product sponsors.
As you review this information, we would like to remind you that we are registered with the U.S. Securities and Exchange Commission (SEC) as a Broker Dealer and we are members of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Organization (SIPC). Our Customer Relationship Summary (Form CRS) contains important information about the types of services we offer along with general information related to compensation, conflicts of interest, disciplinary action and other reportable legal information. Please carefully review and consider the information in each section below.
When you establish an account with a product sponsor or insurance carrier through us, the services we provide will vary from product to product. For example, private equity funds do not allow for buying and selling at the client’s discretion post implementation. Thus, we will only help with implementation and ministerial account servicing needs. However, variable insurance products will typically offer a variety of investment subaccounts, which clients are typically allowed to trade in and out of inside the product. 529 College Savings Plans may offer the same trading capability inside the plan. When you utilize these products, our role is to help you implement the product, assist with implementing your investment strategy and assist with ministerial account servicing needs. We do not earn compensation from trading inside these products. As detailed below, our compensation is earned when the products are implemented, and some will offer compensation that is not tied to buying and selling within the product. Please refer to the products prospectus or other offering documents for specific details.
Our product sponsors offer many different account types including individual and joint accounts, custodial accounts, estate and trust accounts, partnership accounts, corporate accounts, IRAs, Roth IRAs and other types of retirement accounts.
It is important for you to understand that when our Registered Representatives make a recommendation to you, we are obligated to ensure the recommendation is in your best interest, considering reasonably available alternatives, and based on your stated investment objective, risk tolerance, liquidity needs, time horizon, financial needs, tax status, and other financial information you provide to your Registered Representative and us. You may accept or reject any recommendation. It is also your responsibility to monitor the investments in your account, and we encourage you to do so regularly. We do not commit to provide on-going monitoring of your account.
Please also consider that from time to time we may provide you with additional information and resources to assist you with managing your account. This may include but is not limited to educational resources, sales and marketing materials, performance reports, asset allocation guidance, and/or periodic account reviews. When we offer these services and information, we do so as a courtesy to you. These activities are not designed to monitor specific investment holdings in your account, they do not contain specific investment recommendations about investment holdings, and you should not consider them a recommendation to trade or hold any particular securities. Upon your request, we will review such information and reports with you and may provide you with investment recommendations, but we are not under a specific obligation to do so.
It is important for you to understand that all investment recommendations and activities involve risk, including the risk that you may lose your entire principal. Further, some investments have low liquidity characteristics. Thus, you may not be able to sell out of an investment at your discretion. Higher-risk investments may have the potential for higher returns but also for greater losses. The higher your “risk tolerance,” meaning the amount of risk or loss you are willing and able to accept in order to achieve your investment goals, the more you may decide to invest in higher-risk investments offering the potential for greater returns. Some of the products offered by us do not allow for diversification inside the product as they may have a singular focus. When diversification inside a product is available, we attempt to align risk tolerances with investment needs to offer you different investment objectives from which to choose (see below). You should select the investment objective and risk tolerance best aligned with your account goals and needs.
Investment goals typically have different time horizons and different income and growth objectives. Generally, investment goals are on a spectrum, with “Capital Preservation” investors typically holding the smallest percentage of higher- risk investments, followed by “ Income” investors holding some higher-risk investments, followed by “Growth and Income” investors holding more higher risk investments and finally “Growth” investors holding a significant portion of their portfolio in higher-risk investments. Risk tolerance also varies and we measure it on a continuum that increases from “Risk Averse” to “Highly Aggressive”. See the chart below for details.
Account Minimums and Activity Requirements
Account minimums are determined by the product sponsor. Please refer to the product prospectus, or other offering documents for specific details.
Annuities are long-term financial products designed for retirement purposes. In essence, annuities are contractual agreements in which payments are made to an insurance company, which agrees to pay out an income or a lump sum amount at a later date. There are contract limitations and fees and charges associated with annuities, administrative fees, and charges for optional benefits. They also may carry early withdrawal penalties and surrender charges and carry additional risks such as the insurance carrier’s ability to pay claims. Moreover, variable annuities carry investment risk similar to mutual funds. Investors should carefully review the terms of the variable annuity contract and prospectus before investing.
We currently offer thousands of mutual funds varying in share class structure and investment style. If you invest in mutual funds, we may receive direct and indirect compensation in connection with such mutual fund investments, as described below.
12b-1/Shareholder Service Fees
Annual 12b-1 fees, also known as trails, are paid by the fund and paid to us out of fund assets under a distribution and servicing arrangement to cover distribution expenses and sometimes shareholder service expenses that we may provide on the fund’s behalf. Shareholder servicing fees are paid to respond to investor inquiries and provide investors with information about their investments. These fees are asset-based fees charged by the fund family. These fees range from 0.00% to 1.00%. These fees may be passed on to us and may in turn be passed on to your Registered Representative as a commission.
Front-end Sales Charge Fees/Contingent Deferred Sales Charges (CDSC)
Front-end sales charge fees may be charged and paid to us, including your Registered Representative, when you purchase a fund. The front-end sales charge is deducted from the initial investment on certain share classes. This charge normally ranges from 0.00% to 5.75%. Some purchases may qualify for a reduced front-end sales charge due to breakpoint discounts based on the amount of transaction and rights of accumulation. In addition, some purchases may qualify for a sales charge waiver based on the type of account, and/or certain qualifications within the account. You should contact your Registered Representative if you believe you are eligible for sales charge waivers.
CDSC is a charge you pay upon withdrawal of money from a fund prior to the end of the fund’s CDSC period. CDSC charges range from 0.00% to 5.50%. CDSC periods can range from zero to seven years. This charge typically exists only on share classes that do not have a front-end sales charge. It is sometimes referred to as the back-end load. CDSCs are not charged when you purchase a fund. The fee charged will depend on the share class purchased by the investor. A CDSC is not passed on to your Registered Representative. You can find a description of the amount and payment frequency of all fees and expenses charged and paid by the fund in the fund’s prospectus. Fees and expenses disclosed in the fund’s prospectus are charged against the investment values of the fund.
There are two types of 529 plans—college savings plans and prepaid tuition plans. The college savings version allows earnings to grow tax-deferred and withdrawals are tax-free when used for qualified education expenses. Every state offers at least one of these types of plans. Some states offer both, and a consortium of private colleges also offers a prepaid tuition plan. With college savings plans, students of all ages can save for all college costs, including tuition, fees, room, board, textbooks and computers (if required by the school). Beginning in 2018, 529 Savings Plans can be used to pay for K-12 tuition, up to $10,000 per year per beneficiary. All 529 college savings plans have fees and expenses. Not only do these charges vary among 529 plans, but also, they can vary within a single plan. Like mutual funds, a single college savings plan may offer more than one “class” of shares to investors. Often referred to as A, B or C classes, units or fee structures, each class has different fees and expenses. You can look at the offering document to see if a particular college savings plan offers more than one class.
Here are some of the most common fees, charges and expenses found in college savings plans: Enrollment Fees, Annual Maintenance Fee, Sales Charge (Front-End Sales Load), Deferred Sales Charge, Administration/Management Fee, Underlying Fund Expenses, 12b-1/Shareholder Service Fees.
Our current alternative investment offerings are private equity funds and pooled investment vehicles. Commissions earned by us generally range from 3-5% of the capital invested. Investors within the private equity funds also incur other fees through the Fund’s operation which may reduce profitability and , thus, reduce distribution payouts to investors. These fees include, but are not limited to organizational, tax, legal, audit and fund management fees and fees charged by third-party service providers. These fees are not typically shared with us. However, some of the private equity funds may share a portion of the carried interest earned by the manager with the broker-dealer. Please refer to the fund specific private placement memorandums for more detailed information on fees paid.
Equity Indexed Annuities (EIAs)
EIAs have characteristics of both fixed and variable annuities. Their return varies more than a fixed annuity, but not as much as a variable annuity. So EIAs give you more risk (but more potential return) than a fixed annuity but less risk (and less potential return) than a variable annuity. EIAs offer a minimum guaranteed interest rate combined with an interest rate linked to a market index. Because of the guaranteed interest rate, EIAs have less market risk than variable annuities. EIAs also have the potential to earn returns better than traditional fixed annuities when the stock market is rising. The selling broker is paid a commission for these products; the payout options vary by company, so it’s important to ask your Registered Representative about these charges.
Equity indexed annuities typically do not have an up-front sales charge, but there are often significant surrender fees. Surrender fees are fees that you pay if you withdraw your money before the surrender period ends. Review the product prospectus for this information. Further, because of how the equity indexed annuities are designed, it is important to consider the cost of being tied to the guaranteed interest rate versus investing in products with the potential for higher returns. Surrender fees are solely paid to the insurance company and they are not shared with us.
We offer variable universal life insurance products. Deciding which insurance product(s) to purchase can be difficult. It is important for clients to work with their registered representative to evaluate how a particular insurance product and its features fit their individual needs and objectives. An important component of any insurance review in the selection process includes carefully reading documents such as the product brochure and sample policy. For variable life products, these documents would include the product prospectus and variable insurance investment subaccount prospectus materials. Each document contains important information that will help clients make an informed decision. Registered representatives will provide these documents for client review and will also answer client questions such as which guarantees are provided by the insurance product, what optional benefits and riders are available, and how variable insurance investment subaccounts are priced.
Similar to Index Annuities, Variable Life insurance products often have significant surrender fees. Surrender fees are fees that you pay if you withdraw your money before the surrender period ends. Review the product prospectus for this information. Surrender fees solely paid to the insurance company and they are not shared with us.
Our Compensation and Conflicts of Interest
Conflicts of interest exist when we provide services to you. A conflict of interest is a situation in which we engage in a transaction or activity where our interest is materially averse to your interest. The mere presence of a conflict of interest does not imply that harm to your interests will occur, but it is important that we acknowledge the presence of conflicts. Moreover, our regulatory obligations require that we establish, maintain, and enforce written policies and procedures reasonably designed to address conflicts of interest associated with our recommendations to you.
Our conflicts of interest are typically the result of compensation structures and other financial arrangements between us, our Registered Representatives, our clients and third parties. We offer a broad range of investment services and products and we receive various forms of compensation our product sponsors and insurance carriers. Securities rules allow for us, our Registered Representatives, and our affiliates to earn compensation when we provide services to you. However, the compensation that we and our Registered Representatives receive varies based upon the product or service you purchase, which creates a financial incentive to recommend investment products and services that generate greater compensation to us.
We are committed to taking appropriate steps to identify, mitigate and avoid conflicts of interest to ensure we act in your best interest when providing product recommendations to you. Below you will find additional information related to our conflicts of interest. This information is not intended to be an all-inclusive list of our conflicts, but generally describes those conflicts that are material. In addition to this disclosure, conflicts of interest are disclosed to you in your account agreement(s) and disclosure documents, our product guides and other information we make available to you.
Compensation we receive from clientsTransaction-based conflicts
In most circumstances, when you finalize an investment into a product, we earn a commission which is paid by the product sponsor. In certain circumstances, such as investment in a private placement or an “A” Share mutual fund or “A” Share 529 savings plan, a portion of your investment is deducted as a selling concession and it is paid to us. More details on share classes is provided below. Where these fees apply, the more transactions you enter into, the more compensation that we and your Registered Representative receives. This compensation creates an incentive for us to recommend that you buy rather than sell or hold, these investments. We also have an incentive to recommend that you purchase investment products that carry higher fees, instead of products that carry lower fees or no fees at all.
Compensation we receive from third parties
Third-party payments we receive may be based on new sales of investment products, creating an incentive for us to recommend you buy and sell, rather than hold, investments. Further, we have an incentive to recommend investment products and services that generate greater payments to us. This compensation generally represents an expense embedded in the investment products and services that is borne by investors, even where it is not paid by the Product Sponsor and not directly from the investment product or other fees you pay. The types of third-party compensation we receive include:
Ongoing compensation from Product Sponsors may be received by us and shared with our Registered Representatives. This compensation (commonly known as trails, service fees or Rule 12b-1 fees in the case of mutual funds) is typically paid from the assets of the investment product under a distribution or servicing arrangement and is calculated as an annual percentage of invested assets. The amount of this compensation varies from product to product. We have an incentive to recommend that you purchase and hold interests in products that pay us higher trails.
Product Share Classes
Some Product Sponsors offer multiple structures of the same product (e.g., mutual fund share classes) with each option having a unique expense structure, and some having lower costs to you as compared to others. We are incentivized to make available those share classes or other product structures that will generate the highest compensation to us.
The mutual fund industry has developed a multiple share class structure for mutual funds, which provides investors options for paying sales charges and service fees. Though there are several types of share classes, among the most common share classes available to retail investors are Class A, Class B, and Class C. While there is no standard, industry wide definitions of these classes (each mutual fund defines its share classes in its prospectus), some of the typical differences are discussed below. You should note that each class generally has different fees and expenses, and therefore performance results will differ when those fees and expenses are included in a performance presentation. You should also note that the length of time you expect to hold your investment in a mutual fund may play an important role in determining which share class is most appropriate for you, and you should discuss your expectations in this regard with your registered representative.
Class A – This class usually carries a front-end sales charge. This means that a sales charge is deducted from your investment each time you purchase additional shares. Typically, Class A shares have a lower expense ratio (total annual fund operating expenses as a percentage of the mutual fund’s assets) compared to the other share classes of the same mutual fund offered to similar account types, which means that ongoing costs may be lower than the costs associated with other share classes of the same mutual fund. Many mutual funds offer “breakpoint” discounts for large investments within the mutual fund group/family. These breakpoints are described in the mutual fund’s prospectus.
Class B – Rather than imposing a sales charge at the time of initial investment as with Class A shares, Class B shares are characterized by a back-end or contingent deferred sales charges (also known as a “CDSC”), which means that you may pay a sales charge when you redeem (sell) mutual fund shares. The amount of the CDSC as a percentage of your investment normally declines over time and eventually is eliminated the longer you hold your shares (the period of decline may last anywhere from five to eight years depending on the particular mutual fund). Once the CDSC is eliminated, Class B shares usually convert to Class A shares. Until this conversion takes place, Class B shares will generally have higher 12b-1 fees than Class A shares and, as a result, the overall expense ratio for Class B shares will be generally higher than that of Class A shares.
Class C – Class C shares are generally characterized by a level asset-based distribution fee, and, similar to a Class B share, a CDSC. However, unlike Class B shares, the possibility of incurring a CDSC if you sell your shares generally goes away after a short period of time (usually one year). Class C shares may have the same 12b-1 fees as Class A and B shares, but the level asset-based sales charge will increase the ongoing asset-based fees of the fund. As a result, Class C shares will almost always have a higher total operating expense ratio than Class A shares.
Further explanation of mutual fund share classes and their related fees is available on the Financial Industry Regulatory Authority’s website at www.finra.org (click on the “Investors ” tab).
Compensation Related to Proprietary Products
Our recommendations can include a recommendation to invest in a product or service that is managed, issued or sponsored by us or our affiliates. We and our affiliates will receive additional compensation or economic benefits from investments by you in such products, including, but not limited to, management fees and service related fees. Please refer to the product prospectus or other offering document for specific details. The compensation related to these may be greater than similar products provided by third parties. Thus, we have an incentive to recommend investments in proprietary/affiliated products.
Compensation received by
Registered Representatives are compensated with commissions, paid to the firm and provided by the product sponsor. This compensation may vary by the product. In addition to upfront-transaction based compensation, some products feature on-going residual or “trail” payments. Thus, Registered Representatives are incentivized to recommend products that have higher fees as well as those with on-going payments.
Typically, a Registered Representative’s payout schedule (periodically adjusted by us at our discretion) increases with production and asset levels. The same payout schedule is reduced when Registered Representatives discount certain client fees and commissions. As a result, Registered Representatives have an incentive to provide recommendations that result in selling more investment products and services, as well as investment products and services that carry higher fees.
Registered Representatives have an incentive to recommend you rollover assets from a Qualified Retirement Plan (QRP) to an Individual Retirement Account (IRA) through our product sponsors because of the compensation they will receive. We maintain policies and procedures designed to ensure that rollover recommendations are in your best interest.
Registered Representatives may be motivated to place trades ahead of clients in order to receive more favorable prices than their clients.
Registered Representatives who are transitioning through a succession plan may be incentivized to make brokerage recommendations designed to increase the value of their “book of business” through asset accumulation or brokerage trades that are not in your best interest. Registered Representatives who receive clients from a retiring Registered Representative are incentivized to meet growth goals and may make recommendations not in your best interest.
Updated Privacy Notice: click here.
California Consumer Privacy Act
Effective January 1, 2020, if you are a California resident, you have expanded rights regarding the collection and disclosure of information about yourself as part of the California Consumer Privacy Act of 2018 (CCPA).
Only you or your authorized representative may make these requests. You may make requests for data disclosure or portability no more than twice in a 12-month period. In your request, you must provide enough information to allow us to verify you are the person about whom we collected personal information, or their authorized representative. We can’t respond to your request if we can’t verify your identity. We will only use the information you provide in a request to verify your identity. Authorized representatives will be contacted to provide a signed, written permission to make such requests or power of attorney. You may also make a request on behalf of your minor child.
If you have questions about any of these rights, please call us at 866.569.2450. We will not discriminate against you for exercising any of your CCPA rights.
Information We Collect
The types of personal information the Firm collects and shares for everyday business purposes and for marketing purposes depends on the product or service you have or for which you are applying. This information may include, but may not be limited to:
- Name, Social Security number and income
- Account balances and payment history
- Credit history and credit scores
Right to Know
In accordance with the CCPA, you have the right to know what information we have collected about you. You can request us to disclose this personal information no more than twice in a 12-month period. If you would like a list of the information we maintain, we will email it to you within 45 days of your request. If we require more time (up to 90 days) we’ll let you know this, and the reason why, in writing. Call 866.569.2450 and ask for the Compliance Department or click here to proceed with this request.
Right to Delete
In accordance with the CCPA, you have the right to request that we delete the information we have about you. Larson Financial Holdings, LLC offers several services that require certain information in order to work. Deleting your information can affect your ability to:
• Receive regular newsletter updates
• Receive offers or event invitations
• Access services from our affiliates.
We will attempt to complete your request within 45 days. If we require more time (up to 90 days) we’ll let you know this, and the reason why, in writing. Call 866.569.2450 and ask for the Compliance Department or click here to proceed with this request.
“Do Not Sell”
Larson Financial Holdings, LLC does not now, nor have we in the past, sell or sold consumer information to third parties for financial gain.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section 1798.83, also known as S.B. 27) allows customers to opt out of having your personal information shared for direct marketing purposes. Larson Financial Holdings, LLC does not share your information for direct marketing purposes.