Legal / Disclosure
LEGAL
This site has been published in the United States for residents of the United States. The foregoing has been prepared solely for informational purposes, and it is not an offer to buy or sell or a solicitation of an offer to buy or sell any security or instrument or to participate in any particular trading strategy.
Much of the information offered on this site is offered through third-party independent vendors and non-affiliated market sites. 1879 Advisors® offers no opinion as to the accuracy or timeliness of any information provided within this site, nor offers any guarantees as to the accuracy or timeliness of any information contained within this site. Consumers and/or members of the public should not exclusively rely upon this information when considering investments decisions.
1879 Advisors®, and any of its employees acting as an agent, may transact business in a particular state only if first registered, excluded or exempted from registration requirements either individually or as a firm. In addition, follow-up conversations or meetings with individuals in a particular state by either 1879 Advisors®, or its employees acting as agent to effect transactions in securities or discuss securities, investment planning or other personal investment advice will not be made without first becoming registered, excluded or exempted from registration requirements either individually or as a firm. Member FINRA & SIPC. Securities cleared through Pershing LLC.
With passage of the USA PATRIOT Act and SEC approval of the Treasury Department's Customer Identification Rules, 1879 Advisors® must notify all public and institutional clients of its obligation to verify their identity. Verification of identity will take place through various means, such as comparing information provided by the client against databases like Equifax or Lexis/Nexis, requiring photocopies of a driver's license, passport, or alien registration card, or obtaining other documents of attestation as to that client's identity.
The Management of 1879 Advisors® would like to thank all clients for their cooperation in assisting the firm in doing its part to maintain the integrity of the U.S. securities markets.
DISCLOSURE BROCHURES
THE 1879 Advisors CODE OF ETHICS
1879 Advisors® has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. 1879's Code of Ethics describes the firm's fiduciary duties and responsibilities to clients, and sets forth 1879's practice of supervising the personal securities transactions of supervised persons with access to client information. Individuals associated with 1879 Advisors® may buy or sell securities for their personal accounts identical to or different than those recommended to clients. It is the expressed policy of 1879 Advisors® that no person employed by 1879 Advisors® shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on the investment decisions of advisory clients.
To supervise compliance with its Code of Ethics, 1879 Advisors® requires that anyone associated with this advisory practice with access to advisory recommendations provide initial/annual securities holdings reports and quarterly transaction reports to the firm's Chief Compliance Officer. 1879 Advisors® requires such access persons to also receive approval from the Chief Compliance Officer prior to investing in any IPOs or private placements (limited offerings).
1879 Advisors® requires that all individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 1879's Code of Ethics further includes the firm's policy prohibiting the use or misuse of material non-public information. Any individual not in observance of the above may be subject to discipline.
1879 Advisors® will provide a complete copy of its Code of Ethics to any client upon written request to the Chief Compliance Officer at 1879’s principal address.
HOW TO REGISTER A COMPLAINT
All inquiries, complaints and other correspondence should be sent to:
1879 Advisors
Attn: Chief Compliance Officer
119 Birch Hill Road
Locust Valley, NY 11560
DISCLOSURE
VARIABLE ANNUITY DISCLOSURE
At Bruderman Brothers, LLC (BBLLC) we receive compensation from the issuers of all of the variable annuities that are available to our brokerage customers. The compensation includes up-front commissions, trailing commissions, and may include payments for both administrative services that we provide, and payments made in connection with programs that support our marketing and sales-force education and training efforts (referred to here as "Sponsorship Programs").
SPONSORSHIP PROGRAMS
The variable annuity issuers that participate in the Sponsorship Programs are listed in the chart below (Participating Sponsors). The payments made under the Sponsorship Programs are calculated based upon the assets that are invested in the variable annuity contracts issued by the Participating Sponsors (a Participating Annuity), including assets held in fee-based advisory programs at Bruderman Asset Management, LLC (BAM). BBLLC may receive compensation of up to 0.40 percent of the assets invested in a Participating Annuity. For example, if you held $10,000 dollars in a Participating Annuity for one year, BBLLC could receive up to $40. BBLLC Financial Advisors do not receive any part of these payments. We believe that these programs do not compromise the advice your Financial Adviser gives you.
PARTICIPATING SPONSORS
AIG SunAmerica Life
Assurance Company
Allstate Life Insurance Company
American Skandia, a Prudential Financial Company
AXA Distributors LLC
Genworth Financial
The Hartford
Voya Financial
Jackson National Life Insurance Company
John Hancock Life Insurance Company
Lincoln Financial Distributors, Inc.
MassMutual Life Insurance Company
Metlife Investors Insurance Company
Nationwide Life Insurance Company
Pacific Life Insurance Company
Prudential Annuities Life Insurance Corp.
Scudder Distributors, Inc.
Sun Life Financial Distributors, Inc.
Transamerica Capital, Inc.
USAllianz Investor Services, LLC
MORE INFORMATION
Information about a variable annuity's fees and expenses may be found in the fee table located in the variable annuity contract document.
Variable annuities are sold by prospectus, which contains more complete information including investment objectives, risk factors, fees, surrender charges and other costs as well as other information about the investment company. Read it carefully before investing or sending money.
Investors are strongly advised to consider the investment objectives, risks, and charges and expenses of the investment company carefully before investing. A prospectus for any of the above referenced Variable Annuities can be obtained by calling our Investor Services Department at (800) 433-0323.
MUTUAL FUND DISCLOSURE
At Bruderman Brothers, LLC (BBLLC) we receive compensation from all of the mutual fund families that are available to our brokerage customers. These payments include commissions (sometimes referred to as "loads"), trailing commissions (including so-called 12b-1 payments), payments for administrative services that we provide, and payments made in connection with programs that support our marketing and sales-force education and training efforts (referred to here as "Sponsorship Programs").
SPONSORSHIP PROGRAMS
The mutual fund families that participate in the Sponsorship Programs are listed in the chart below. The payments made under the Sponsorship Programs are calculated based upon the assets that are held at the participating mutual fund family, including assets held in fee-based advisory programs at Bruderman Asset Management, LLC (BAM). BBLLC may receive compensation of up to 0.50 percent of the assets held at the mutual fund family. For example, if you held $10,000 dollars with a participating mutual fund family for one year, BBLLC could receive up to $50. BBLLC Financial Advisors do not receive any part of these payments. BBLLC also assesses a $15 ticket charge for automated purchases of mutual funds. Generally, the mutual fund families that participate in the Sponsorship Programs may subsidize some of these ticket charges. (American Funds does not subsidize ticket charge reductions.) As indicated on the chart below, in some cases the ticket charge is waived completely, and in other cases it is discounted. Every mutual fund offered by BBLLC also may be purchased without a ticket charge by processing the transaction with a check and application sent directly to the mutual fund company. We believe that these programs do not compromise the advice your Financial Advisor gives you.
MUTUAL FUNDS SPONSORSHIP PROGRAM
AIG SunAmerica
AIM Investments
Alliance Bernstein
Allianz Global Investors
BlackRock
Columbia Funds
Delaware Financial
Dreyfus (load)
Eaton Vance Managed Investments
Federated Fidelity Advisor
Franklin Templeton Investments
The Hartford (Planco/Hartford)
Voya Financial
IXIS Asset Management
John Hancock Funds
MFS Investment Management
Oppenheimer Funds
Phoenix Investments
Pioneer Investments
Prudential Financial
Putnam Investments
Scudder Investments
Van Kampen Investments
WM Group of Funds
TRAILING COMMISSIONS INFORMATION
Many mutual funds pay BBLLC trailing commissions (including so-called 12b-1 payments). BBLLC usually retains a portion of these fees as compensation for services we provide, and pays the remainder to its Financial Advisors, as compensation for the services that they provide to their clients.
MORE INFORMATION
Information about a mutual fund's fees and expenses may be found in the fee table located in the fund's prospectus. Also, the fund's statement of additional information contains important information that you may wish to read.
Investors should carefully consider the investment objectives, risks, charges and expenses of any mutual fund they intend to invest in. This and other important information is contained in the prospectuses, which can be obtained from your financial adviser and should be read carefully before investing. Investments are not FDIC-insured, nor are they deposits of or guaranteed by a bank or any other entity.
Investors are strongly advised to consider the investment objectives, risks, and charges and expenses of the investment company carefully before investing. A prospectus for any of the above referenced Mutual Funds can be obtained by calling our Investor Services Department at (800) 433-0323.
BUSINESS CONTINUITY PLANNING
January 2020
Bruderman Brothers, LLC has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.
CONTACTING US
If after a significant business disruption you cannot contact us as you usually do, you should call our alternative number, below, or visit our web site, www.1879advisors.com, for updated information. If you cannot contact us, our clearing firm is Pershing, LLC, 1 Pershing Plaza, Jersey City, NJ 07399 (201) 413-2000.
OUR BUSINESS CONTINUITY PLAN
We plan to quickly recover and, where reasonable, resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.
Our clearing firm, Pershing, LLC, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised, by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within 24 hours. Your orders and requests for funds and securities could be delayed during this period.
VARYING DISRUPTIONS
Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within 24 hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 48 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our customer numbers (845-368-2900 or the alternate number, 800-433-0323) or website of current contact information. If the business disruption is so severe that it prevents us from remaining in business, we will assure our customer's prompt access to their funds and securities.
FOR MORE INFORMATION
If you have questions about our business continuity planning, you can contact Miles J. Edwards, Esq., General Counsel / Chief Compliance Office by phone at 646-827-7794 or by email at medwards@bruderman.com.
PROXY VOTING DISCLOSURE
Bruderman Asset Management, LLC (BAM) does not generally have authority to vote proxies on behalf of clients. The firm does, however, have this authority where it acts as General Partner for private investment vehicles. BAM will vote proxies in the best interests of the partnerships and will disclose material conflicts of interest. BAM's written procedures addressing proxy voting and the handling of material conflicts are available to clients upon written request.
For more information see the Disclosure Brochure