Regulation Best Interest (Reg BI) Compliance Obligation requires that recommended transactions are consistent with the customer’s best interest. It is critical to remember that the risks, rewards and cost advantages of one mutual fund share class versus another must be considered when recommending mutual funds. The following are guidelines for determining which class of shares is best for the customer. Additional information can be found in Mutual Securities’ Written Supervisory Procedures.
· Class B or C shares generally should not be recommended to customers making purchases in large amounts that may qualify for lower costs because of breakpoints, letters of intent, or rights of accumulation available through the purchase of class A shares.
· Class B shares should not be purchased for a customer if the RR knows or has reason to know that the customer will be purchasing additional shares that would take a purchase over a Class A breakpoint within 13 months of the initial purchase.
· Class B shares should not be purchased if potential additional purchases would qualify for a NAV price.
· Class A shares may be more appropriate for a customer who intends to remain invested in the fund for a longer period of time. Over time the higher continuing sales charges of Class B and C shares may exceed the initial load and smaller 12b-1 fees of Class A shares.
· Class C shares may not be economically beneficial for customers with a long-term investment time horizon due to their higher expense ratios and 12b-1 fees. Over time, these increased fees add up and can have negative effect on a portfolio’s rate of return. Additionally, Class C shares typically do not convert to Class A shares and continue to charge higher annual expenses and 12b-1 fees for as long as the shares are held.
· Class C shares may be appropriate for a customer who does not qualify for a reduced Class A initial sales charge and who does not intend to remain invested in the fund for a period during which the fund's Class B shares are subject to a CDSC.
· Some funds waive the sales charge under circumstances specified in the prospectus (e.g., purchases by employees of broker-dealers and their immediate family members). If a Class A sales charge waiver is available, Class A shares will be less costly than Class B or C shares. A CDSC may be imposed on early fund redemptions of Class A shares where a waiver is granted; the prospectus should be consulted.
In addition, Mutual requires the “Mutual Fund Disclosure Form” to be completed any initial mutual fund purchases (including initial purchases at Mutual following a change of broker-dealer), which involve purchases in a new mutual fund family, or purchases totaling $100,000 or more for full or partial investment exchanges, rollovers from an ERISA retirement plan OR IRA to IRA transfers. If you have any questions, please reach out to Compliance via the Power Portal.