Disclosures and Privacy

Documents & Disclosures

Documents & Disclosures – Berthel Fisher & Company Financial Services, Inc. (BFCFS)

Documents & Disclosures – Securities Management & Research, Inc. (SM&R)

Documents & Disclosures – BFC Planning, Inc.

Quality of Execution Reports

In compliance with SEC Rule 11Ac1-6 Quality of Execution, BFCFS & SM&R customers may view a disclosure of the firm’s order routing practice by reviewing the following links. Additionally, if requested, BFCFS & SM&R will provide you with a paper copy of any of the reports.

Revenue Sharing

Berthel Fisher & Company Financial Services, Inc., Securities Management & Research, Inc., BFC Planning, Inc., and Berthel Fisher & Company Insurance, Inc. (collectively referred to as “Berthel Fisher”) offer a wide variety of products and services that are sold through its registered representatives and investment advisors. Sponsors of certain products may, from time to time, share with Berthel Fisher the revenue they receive from those products. Such revenue sharing payments are in addition to commissions, annual service fees (12b-1fees) and other fees and expenses disclosed in the prospectus for a sponsor’s product.

Revenue sharing arrangements could be viewed as providing an incentive to promote a particular sponsor’s product over products sponsored by other sponsors. Therefore, Berthel Fisher believes it is important that you are aware of the possibility that Berthel Fisher may have revenue sharing arrangements with respect to certain sponsors and products. Registered representatives and investment advisors do not receive increased commissions on account of the sale of products that have revenue sharing arrangements.

Revenue sharing varies from product to product and sponsor to sponsor. The revenue sharing payments Berthel Fisher receives from sponsors can be a flat fee or can be based on product sales or assets under management by the sponsor. Berthel Fisher uses payments received through revenue sharing arrangements for operations, including for marketing and providing educational opportunities for its registered representatives and investment advisors. In some situations, Berthel Fisher may share its revenue sharing payments with selling representatives or investment advisors; this sharing has no effect on commissions.

Revenue sharing arrangements are typically explained in a product’s prospectus or offering memorandum. If you would like to know what revenue sharing arrangements Berthel Fisher has with sponsors and products, Berthel Fisher will provide that information upon request. You may visit with your registered representatives and investment advisors, email the Berthel Fisher home office at compliance@berthel.com, or call 319.447.5700 ext 580.