Cambridge Investment Research, Inc. (Cambridge) has prepared this report pursuant to a US Securities and Exchange Commission rule requiring all brokerage firms to make publicly available quarterly reports on their order routing practices. The report provides information on the routing of "non-directed orders" - any order that the customer has not specifically instructed to be routed to a particular venue for execution. For these non-directed orders, Cambridge has selected the execution venue on behalf of its customers.
The report is divided into four sections: one for securities listed on the New York Stock Exchange, one for securities listed on The NASDAQ Stock Market, one for securities listed on the American Stock Exchange or regional exchanges, and one for exchange-listed options. For each section, this report identifies the venues most often selected by Cambridge, sets forth the percentage of various types of orders routed to the venues, and discusses the material aspects of Cambridge's relationship with the venues.
The Business Continuity Plan Summary Disclosure Statement ('the Plan') provides a summary detail on Cambridge's risk mitigation strategy in the event of interruption(s) to daily business operations. Cambridge's Plan is designed to respond to a Significant Business Disruption (SBD) by safeguarding employees' lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm's books and records, and allowing our customers to transact business. The Plan is intended to comply with obligations pursuant to regulatory rules and requirements as promulgated by the Financial Industry Regulatory Authority (FINRA), particularly Rule 4370.
Our Plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm's ability to communicate and do business, such as a fire in our building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, or a wide-scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firms, National Financial Services LLC and Pershing LLC, and other sponsor providers with whom we have agreements. Our firm does not maintain custody of clients' funds or securities, which are maintained at our clearing firms or held directly at other firms, including but not limited to mutual fund companies and insurance companies. In the event of an SBD where you are unable to reach Cambridge and you have an account held directly at one of the firms with which we have an agreement, you are encouraged to call the custodian's direct number found on your account statement.
In the event of an SBD, either external or internal, Cambridge shall establish an ordered dependency list and begin immediately communicating pertinent information with our clients, employees, critical business constituents, critical banks, critical counter-parties, and regulators. The communication options we will employ may include our website, telephone voice mail, secure email, and US postal mail service.
All mission-critical systems are backed up and a copy is stored offsite. Mission-critical systems are defined by Cambridge. In the event of an SBD, these backups will be obtained and restored as necessary.
Regardless of all the effort put forth on this vital concern, we acknowledge that no disaster recovery plan is perfect. The unpredictable nature of disasters precludes absolute preparedness for any plan. Certain situations may arise that affect outside entities upon which we rely for some service or collaboration. It is possible for circumstances to arise outside of what has been defined within the Plan.
This plan is subject to modification, without notice. An updated summary will be promptly posted on our website and customers may alternatively obtain updated summaries by requesting a written copy by mail at 1776 Pleasant Plain Road, Fairfield, Iowa 52556.
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
|Type of Information||Disclosed to a Third Party||Sold|
|Characteristics of Protected Classifications||No||No|
|Internet Activity Information||No||No|
|Audio, electronic, visual, thermal, olfactory||No||No|
|Information regarding minor children Information||No||No|
Cambridge Investment Research, Inc. and its affiliates, including Cambridge Investment Research Advisors, Inc. (hereinafter, collectively referred to as Cambridge) offer a wide variety of products and programs including mutual funds, annuities, life insurance, and investment wrap programs. We collectively refer to these companies as Available Product Companies. Cambridge has entered into various arrangements with some Available Product Companies referred to as revenue sharing arrangements. Although Cambridge endeavors at all times to put the interest of its clients ahead of its own or those of its officers, directors, or representatives (“affiliated persons”), these arrangements could affect the judgment of Cambridge or its affiliated persons when recommending investment products. Because these situations present a conflict of interest that may affect the judgment of our affiliated persons, Cambridge believes it is important that you are aware of our revenue sharing arrangements when you and your rep-advisor evaluate your investment options.
This Code of Ethics (the Code) expresses the policies and procedures of Cambridge Investment Research Advisors, Inc. a federally registered investment adviser (CIRA). It is enforced to ensure that no one is taking advantage of their position, or even giving the appearance of placing their own interests above that of the accounts, clients, and shareholders we are serving. In this regard, Section 204A of the Investment Advisers Act of 1940 (“Act”) requires investment advisers to establish, maintain, and enforce policies designed to prevent the misuse of non-public information by the investment advisor and its supervised persons. Moreover, Section 206 of the Act, among other things, prohibits investment advisers from engaging in any device, scheme, or artifice to defraud any existing or prospective client. In compliance with Sections 204A and 206 of the Act, this Code of Ethics contains provisions reasonably necessary to eliminate the possibility of the misuse of non–public information and/or fraud against any existing or prospective client. This Code also prohibits all supervised persons from trading in any securities listed on the Restricted Trading List without prior written approval.
This section highlights certain key features of the Bank Deposit Sweep Program (the “Program” or “BDSP”). Read the complete Disclosure Document before you decide to participate in the Program. You should consult your broker-dealer or investment representative for more information.
Interest rates/APY will be determined based on prevailing economic and business conditions and are subject to change at any time.
Balances will earn the same rate of interest regardless of the Program Bank with which funds are deposited. Interest rate is based upon each account's Program Deposits in accordance with the above Interest Rate Tiers. The rate of interest is evaluated on a daily basis.
Click here to view the participating banks in the standard network Bank Deposit Sweep Program (BDSP)®.
The Cambridge Insured Bank Deposit Program (the Program) is offered to you by your investment professional or financial organization as a sweep option and is intended for the investment of available cash balances into bank deposit accounts. By selecting the Program as your automatic sweep option, you agree to the terms of the disclosure document and to appoint Pershing LLC as your authorized agent pursuant to these Terms and Conditions.
Click here to view the Cambridge Insured Bank Deposit Program disclosure document.
Click here to view the Rate Disclosure.
Click here to view the Cambridge Insured Bank Deposit Program bank list.
Form ADV 2A is the uniform form used by Registered Investment Advisers to register with both the Securities Exchange Commission (SEC) and state securities authorities. Rep-advisors are required to provide new and prospective clients with a brochure and brochure supplements where information is written in plain English. The Form ADV 2A allows current and prospective clients to evaluate the risks associated with a particular rep-advisor, their business practices, and their investment strategies.
Click here for the most current Part 2A of the Form ADV for Cambridge’s RIA, Cambridge Investment Research Advisors, Inc.
Cambridge financial professionals may offer a wide variety of services to meet your investment goals and objectives. These services may be divided into two categories: investment products offered through a broker-dealer (also known as a “commissionable relationship”), and financial planning and asset management offered through a Registered Investment Adviser (also known as an “advisory relationship”). It is important you carefully consider the differences between a commissionable and advisory relationship when working with your financial professional. There are differences between these accounts, including services provided, costs, and applicable laws and regulations.
Read Understanding the Differences between Commissionable and Advisory Accounts for more information.
Investment products including, but not limited to mutual funds, alternative investments, and variable annuities may offer multiple share class options with varying fees and charges.
When considering investment options, it is important you understand the sales charges (commonly referred to as “loads”), expenses and management fees that you will be charged, as well as potential volume discounts (often referred to as “breakpoints”) to which you may be entitled. Understanding these charges and volume discounts will assist you in identifying the best investment for your particular needs and may help you to reduce the cost of your investment.
You should discuss this information with your financial professional and review each product’s prospectus or offering document and statement of additional information, which are available from your financial professional, to obtain the specific information regarding the charges and discounts associated with a particular investment option.
Though not a comprehensive list, the following represent the most common types of compensation structures associated with share classes:
Sales charge is deducted from your investment at the time you buy the investment. This sales charge is a percentage of your total purchase. Some investments offer volume discounts to the front-end sales charge assessed on certain share classes at predetermined levels of investment.
Back End Load
No sales charge is deducted at the time of purchase; however, you may be required to pay a sales charge known as a contingent deferred sales charge when you sell the shares (the surrender period), depending upon the terms of the particular investment. The load tends to drop, perhaps by a percentage point each year, and then disappears altogether. These share classes usually carry higher internal operating expenses than front end load shares. They may convert to another share class after a predetermined holding period.
An annual charge (also commonly referred to as a “12b-1 fee”) is deducted from your investment for as long as you hold the investment. These share classes typically do not have set surrender periods.
These investments do not impose sales charges and you typically buy shares directly from the investment company. The same funds may be available, with a load, through a financial professional. While no-load funds have no sales charges, they may still charge 12b-1 fees, purchase fees, redemption fees, exchange fees, and account fees in addition to the operating fees that all funds charge.
If permitted by the issuer, some investments may be purchased on a net of commission basis. Load waived shares may be purchased in commission or advisory accounts, depending on the type of investment product. For load waived investments in advisory accounts, your financial professional will be acting as an investment advisor representative of a registered investment adviser (RIA). As such, your financial professional will be acting in a fiduciary capacity and has the obligation to act in your best interest. Your financial professional may provide ongoing investment advice on the investment. Compensation will be paid to the financial professional based on a fee as further outlined in the client investment management agreement.
Please be advised that Cambridge may receive remuneration, compensation, or other consideration for directing client orders to particular broker-dealers or market centers for execution. Unpriced orders can be executed at prices superior to the displayed national best bid or offer and the time the order is received. The source and nature of any compensation received in connection with your particular transaction will be furnished upon request to Cambridge.