CUSTOMER IDENTIFICATION PROGRAM NOTICE
Important Information You Need to Know About Opening A New Account
To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record information that identifies each person who opens an account.
This Notice answers some questions about the firm’s Customer Identification Program.
What types of information will I need to provide?
When you open an account, we are required to collect information such as the following from you:
- Your name
- Date of birth
- Identification number:
- U.S. Citizen: taxpayer identification number (social security number or employer identification number)
- Non-U.S. Citizen: taxpayer identification number, passport number, and country of issuance, alien identification card number, or government-issued identification showing nationality, residence, and a photograph of you.
You may also need to show your driver’s license or other identifying documents.
A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or trust agreement.
U.S. Department of the Treasury, Securities and Exchange Commission, FINRA, and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience, objectives and risk tolerance.
What happens if I don’t provide the information requested or my identity can’t be verified?
We may not be able establish a relationship or carry out transactions for you.
We thank you for your patience and hope that you will support the financial industry’s efforts to deny terrorists and money launderers access to America’s financial system.
Should you have any additional questions concerning our customer identification program, you may use the contact form on our website or submit a written request for additional information to our Customer Service Department located at 80 S.W. 8th Street, Suite 2000 Miami, Florida 33130.
CUSTOMER COMPLAINT NOTICE - SEC Rule 17a-3(a)(18)(ii)
Ashland Securities, LLC, in accordance with Rule 17a-3(a)(18)(ii), is furnishing this statement to provide you with a name, telephone number and address, if you ever need to report or notify us of a possible complaint. If, for any reason, you feel you have a complaint, please contact our offices immediately, by using the contact form on our website, by mail at 80 S.W. 8th Street, Suite 2000 Miami, Florida 33130, Attention: Compliance Department or by phone (305) 279-3176 and ask to speak with our Chief Compliance Officer.
MUTUAL FUNDS BREAKPOINT DISCOUNTS
Before investing in mutual funds, it is important that you understand the sales charges, expenses, and management fees that you will be charged, as well as the breakpoint discounts to which you may be entitled. Understanding these charges and breakpoint discounts will assist you in identifying the best investment for your particular needs and may help you reduce the costs of your investment. This disclosure document will give you general background information about these charges and discounts. However, sales charges, expenses, management fees, and breakpoint discounts vary from mutual fund to mutual fund. Therefore, you should discuss these issues with your financial advisor and review each mutual fund’s prospectus and statement of additional information, which are available from your financial advisor, to get the specific information regarding the charges and breakpoint discounts associated with a particular mutual fund.
Investors that purchase mutual funds must make certain choices, including which funds to purchase and which class share is most advantageous. Each mutual fund has a specified investment strategy. You need to consider whether the mutual fund’s investment strategy is compatible with your investment objectives. Additionally, most mutual funds offer different share classes. Although each share class represents a similar interest in the mutual fund’s portfolio, the mutual fund will charge you different fees and expenses depending upon your choice of share class. As a general rule, Class A shares carry a “front-end” sales charge or “load” that is deducted from your investment at the time you buy fund shares. This sales charge is a percentage of your total purchase. As explained below, many mutual funds offer volume discounts to the front-end sales charge assessed on Class A shares at certain pre-determined levels of investment, which are called “breakpoint discounts.” In contrast, Class B and C shares do not carry any front-end sales charges. Instead, investors that purchase Class B or C shares pay asset-based sales charges, which may be higher than the charges associated with Class A shares. Investors that purchase Class B and C shares may also be required to pay a sales charge known as a contingent deferred sales charge when they sell their shares, depending upon the rules of the particular mutual fund.
Most mutual funds offer investors a variety of ways to qualify for breakpoint discounts on the sales charge associated with the purchase of Class A shares. In general, most mutual funds provide breakpoint discounts to investors who make large purchases at one time. The extent of the discount depends upon the size of the purchase. Generally, as the amount of the purchase increases, the percentage used to determine the sales load decreases. In fact, the entire sales charge may be waived for investors that make very large purchases of Class A shares. Mutual fund prospectuses contain tables that illustrate the available breakpoint discounts and the investment levels at which breakpoint discounts apply. Additionally, most mutual funds allow investors to qualify for breakpoint discounts based upon current holdings from prior purchases through “Rights of Accumulation,” and future purchases, based upon “Letters of Intent.” This document provides general information regarding Rights of Accumulation and Letters of Intent. However, mutual funds have different rules regarding the availability of Rights of Accumulation and Letters of Intent. Therefore, you should discuss these issues with your financial advisor and review the mutual fund prospectus to determine the specific terms upon which a mutual fund offers Rights of Accumulation or Letters of Intent.
Rights of Accumulation – Many mutual funds allow investors to count the value of previous purchases of the same fund, or another fund within the same fund family, with the value of the current purchase, to qualify for breakpoint discounts. Moreover, mutual funds allow investors to count existing holdings in multiple accounts, such as IRAs or accounts at other broker-dealers, to qualify for breakpoint discounts. Therefore, if you have accounts at other broker-dealers and wish to take advantage of the balances in these accounts to qualify for a breakpoint discount, you must advise your financial advisor about those balances. You may need to provide documentation establishing the holdings in those other accounts to your financial advisor if you wish to rely upon balances in accounts at another firm.
In addition, many mutual funds allow investors to count the value of holdings in accounts of certain related parties, such as spouses or children, to qualify for breakpoint discounts. Each mutual fund has different rules that govern when relatives may rely upon each other’s holdings to qualify for breakpoint discounts. You should consult with your financial advisor or review the mutual fund’s prospectus or statement of additional information to determine what these rules are for the fund family in which you are investing. If you wish to rely upon the holdings of related parties to qualify for a breakpoint discount, you should advise your financial advisor about these accounts. You may need to provide documentation to your financial advisor if you wish to rely upon balances in accounts at another firm.
Mutual funds also follow different rules to determine the value of existing holdings. Some funds use the current net asset value (NAV) of existing investments in determining whether an investor qualifies for a breakpoint discount. However, a small number of funds use the historical cost, which is the cost of the initial purchase, to determine eligibility for breakpoint discounts. If the mutual fund uses historical costs, you may need to provide account records, such as confirmation statements or monthly statements, to qualify for a breakpoint discount based upon previous purchases. You should consult with your financial advisor and review the mutual fund’s prospectus to determine whether the mutual fund uses either NAV or historical costs to determine breakpoint eligibility.
Letters of Intent – Most mutual funds allow investors to qualify for breakpoint discounts by signing a Letter of Intent, which commits the investor to purchasing a specified amount of Class A shares within a defined period of time, usually 13 months. For example, if an investor plans to purchase $50,000 worth of Class A shares over a period of 13 months, but each individual purchase would not qualify for a breakpoint discount, the investor could sign a Letter of Intent at the time of the first purchase and receive the breakpoint discount associated with $50,000 investments on the first and all subsequent purchases. Additionally, some funds offer retroactive Letters of Intent that allow investors to rely upon purchases in the recent past to qualify for a breakpoint discount. However, if an investor fails to invest the amount required by the Letter of Intent, the fund is entitled to retroactively deduct the correct sales charges based upon the amount that the investor actually invested. If you intend to make several purchases within a 13 month period, you should consult your financial advisor and the mutual fund prospectus to determine if it would be beneficial for you to sign a Letter of Intent.
As you can see, understanding the availability of breakpoint discounts is important because it may allow you to purchase Class A shares at a lower price. The availability of breakpoint discounts may save you money and may also affect your decision regarding the appropriate share class in which to invest. Therefore, you should discuss the availability of breakpoint discounts with your financial advisor and carefully review the mutual fund prospectus and its statement of additional information, which you can get from your financial advisor, when choosing among the share classes offered by a mutual fund. If you wish to learn more about mutual fund share classes or mutual fund breakpoints, you may wish to review the investor alerts available on the FINRA Web site. http://www.finra.org/Investors/ProtectYourself/InvestorAlerts/MutualFunds/p006022
You may also visit the mutual fund companies web sites available to the general public.
Mutual funds shares are typically offered with various pricing structures. These different types of shares are divided into “classes” and each of these fund classes has unique features and expenses. The following information is a general discussion of the features of common class shares; however specific details may vary from product to product. Please consult the product prospectus for additional information on charges and expenses, as well as any additional share classes that may be available.
Class A Shares: These shares typically charge a “front-end” sales charge. When you purchase a mutual fund with a front-end sales charge, a portion of the dollars you pay are not invested but retained by the mutual fund to cover certain distribution and commission expenses. Class A shares may impose an asset-based charge that is generally lower than the asset-based charges imposed by other mutual fund classes.
A class A mutual fund may offer you a discount on the front-end sales charge if you: make a large purchase, already hold mutual funds offered by the same fund family (rights of accumulation), or if you commit to regularly purchasing the mutual fund’s shares (letter of intent).
Class B Shares: Class B shares typically do not impose a front-end sales charge, but they do have asset-based sales charges that may be higher than those you would incur if you purchased A shares. Class B shares also normally impose a “contingent deferred sales charge” (CDSC) which you pay when you sell your shares. For this reason, these should not be referred to as “no-load” shares.
The CDSC normally declines and is eventually eliminated the longer you hold your shares. Once it is eliminated the Class B shares often convert to Class A shares. Since Class B shares do not impose a front-end sales charge, all of your dollars are immediately invested; however your expenses, as measured by the expense ratio (12b-1 fees), may be higher.
Class C Shares: These shares usually do not impose a front-end sales charge on the purchase, so the full dollar amount you pay is immediately invested. Class C shares often impose a charge if you sell your shares within a short time of the purchase date; usually one year. Class C shares typically impose higher asset-based sales charges than Class A shares, and since they generally do not convert into Class A shares, their asset-based sales charge will not be reduced. Class C shares do not impose a sales charge at the time of purchase, but may impose a CDSC or other redemption fees. In most cases, the expense ratio (12b-1 fees) is higher than Class A shares and Class B shares, if the shares are held for a longer period.
Should you have any additional questions concerning mutual fund breakpoint discounts, you may use the contact form on our website or submit a written request for additional information to our Customer Service Department located at 80 S.W. 8th Street, Suite 2000 Miami, Florida 33130.
RETAIL INVESTOR1 RELATIONSHIP SUMMARY
Ashland Securities, LLC (Ashland Securities or Firm) is registered with the Securities and Exchange Commission (SEC) as a broker-dealer and is a member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). We offer Merger and Acquisition, Corporate Advisory and Private Placement services through investment bankers and institutional placement agents (collectively, our “Advisors”). We hold no customer assets, nor do we trade public securities. We have no customer accounts.
There are free and simple tools available to investors to research firms and financial professionals at www.Investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisers, and investing.
Brokerage and investment advisory services and fees differ, and it is important for you to understand these differences. You should carefully consider which types of accounts and services are right for you. This document gives you a summary of the types of services we provide and how we earn our fees. Please ask us for more information. There are some suggested questions on page 2.
Relationships and Services.
What investment services and advice can you provide me?
· Our Advisors offer Merger and Acquisition and Corporate Advisory services to business owners, corporations, and institutional investors.
· Our Advisors also offer Private Securities to institutional investors and may offer, to a lesser extent, Private Securities to Retail Investors that are accredited investors.
· We offer a limited selection of investments, specifically Private Securities. Other firms could offer a wider range of choices, some of which might have lower costs.
· We are not required to, nor do we monitor your portfolio or investments on an ongoing basis.
Fees, Costs, Conflicts, and Standard of Conduct
What fees will you pay?
· The fees we earn on Private Securities are typically paid by the Issuer, not you.
Our Obligations to Retail Investors when we provide a Recommendation.
When we provide a Retail Investor with a recommendation, we have to act in their best interest and not put our interest ahead of theirs. At the same time, the way we make money creates some conflicts with their interests. Retail Investors should understand and ask us about these conflicts because they can affect the recommendations we provide them with.
How does the Advisor make money?
· Your Advisor has an incentive to offer or recommend certain investments, such as a Private Security, and the Advisor’s compensation is often dependent upon the amount that you invest, which can create a conflict of interest and affect the recommendations that we provide you. Your Advisor can receive both cash and non-cash compensation from our client, the Issuer.
Do we or your Advisor have legal or disciplinary history?
· Ashland Securities, LLC does not have any legal or disciplinary events.
· Some of our Advisors may have legal or disciplinary history. Visit Investor.gov/CRS for a free and simple search tool to research our firm and our Advisors.
· To report a problem to the SEC, visit Investor.gov or call the SEC’s toll‐free investor assistance line at (800) 732‐0330. To report a problem to FINRA, visit finra.org/investors/have-problem. If you have a problem with your investment or Advisor, contact us in writing at the address below
For additional information about our Advisors and our services, visit BrokerCheck (BrokerCheck.Finra.org), our web site (www.ashlandsecurities.com) or call or write:
Ashland Securities, LLC
80 S.W. 8th Street
Miami, Florida 33130
Ask our Advisors these key questions about our investment services.
1. What are the most common conflicts of interest? Explain how you will address those conflicts when providing services to me.
2. How will you choose investments you recommend to me?
3. Help me understand how any fees and costs might affect my investments.
4. Do you or your firm have a disciplinary history? If so, for what type of conduct?
5. What is your relevant experience, including your licenses, education, and other qualifications?
6. Who is the primary contact person for my investment? If I have concerns about how this person is treating me, who can I talk to?
- The term “Retail Investor” as used herein refers to a natural person, or the legal representative of such natural person, who: (A) receives a recommendation of any securities transaction or investment strategy involving securities from a broker-dealer; and (B) uses the recommendation primarily for personal, family, or household purposes.