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About Our Company

Your Rights and Responsibilities as a Raymond James Client

Services for Your Investment and Financial Planning Needs

What our tradition of excellence means to you

Preservation of principal, generation of income and capital appreciation through asset allocation in long-term investments are foremost among the objectives for our financial advisors’ clients. But our aspirations do not stop there. We believe that clients deserve even more, including – but certainly not limited to – a knowledgeable, independent financial advisor to work with them, experienced associates to execute and process transactions, a state-of-the-art computer system to generate comprehensive account statements, and highly regarded research groups to review investment alternatives before they are offered.

In short, Raymond James provides a wide variety of services to our financial advisors that help meet the needs of their clients, from the most sophisticated financial planning client to the first-time investor, from institutions and municipalities to major corporations and fledgling businesses.

Integral to our service commitment is the selection of the best people to serve Raymond James financial advisors and their clients. These are people with high integrity and ethics who are driven to excel. Meeting clients’ financial planning and investment needs – first by striving to protect their principal and its buying power from inflation, then by working to enhance their financial position through income generation and capital appreciation – is our primary goal.

Our business is people and their financial well-being, and our objective is to serve them effectively, efficiently and distinctively – whatever their financial planning and investment needs – by providing the following:

Adjustable coupon investments
Agency securities
Alternative investments
Asset allocation models
Asset management
Cash management services
Cashless stock options
Common stocks
Convertible bonds
Corporate bonds
Fee-based accounts
Financial planning
      Early retirement planning
      Education planning
            529 Plans
      Estate planning
      Traditional retirement planning
Government Securities
Individual retirement accounts
      Roth
      Simple
      Traditional
Insurance
      Annuities
      Disability
      Life
      Long-term care
International investments
Investment banking
      Acquisitions
      Mergers
      Underwritings
            Primary
            Secondary
Listed stocks
Merchant banking
Mortgage-backed securities
Municipal bonds
Mutual funds
      Closed-end
      Open-end
New issue syndications
Online client services
Options
Over-the-counter stocks
Pension management
Preferred stocks
Profit sharing account management
Public financing
Raymond James Charitable Endowment Fund
Ready Access Account (margin loan)
Registered securities
Research reports
      Asset managers
      Fixed income
      International
      Mutual funds
      Stocks
Restricted securities
Small business pension planning
Transfer to beneficiary agreements
Trust services
Agent
Custodian
Personal and charitable
Personal representative
Trustee or co-trustee
Unit investment trusts
Venture capital
Wrap accounts

* Raymond James Bank, FSB, member FDIC, a federally chartered savings bank, is affiliated with Raymond James & Associates and Raymond James Financial Services. Unless otherwise specified, products purchased from or held at Raymond James & Associates are not insured by the FDIC, are not deposits or other obligations of Raymond James Bank, are not guaranteed by Raymond James Bank and are subject to investment risks, including possible loss of the principal invested.

Communicating with Your Financial Advisor.

Your financial advisor is available to answer your questions and discuss your investment strategies during normal business hours. Appointments can generally be arranged at a time convenient to you. Your financial advisor is responsible for explaining all pertinent aspects of each investment that you consider, particularly risk factors, realistic rates of return and liquidity. You also have every right to ask for literature and receive prospectuses when appropriate. If you do not clearly understand what you have read, please ask your financial advisor to explain the material to you. Never, under any circumstances, approve a financial plan or initiate a transaction until you clearly understand what you are agreeing to and/or buying or selling. For quotes and current marketing information, please feel free to call at any time. If you financial advisor is not available, you may contact the manager of the branch office or our Client Services Department at 800-647-SERV (7378). If you use voice mail or e-mail, please do not leave orders or other time-sensitive messages.

Failure to apprise your financial advisor or, in the event he or she cannot be reached, Raymond James of an address change could, under state law, result in assets within an inactive account being surrendered to the state.

Communication from Our Firm.

Among the primary communication clients receive directly from our firm are trade confirmations; monthly, quarterly and/or year-end account statements – in hard copy and/or electronically online; notification of the availability of semiannual statements reporting Raymond James & Associates’ financial condition; and our quarterly newsletter, Financial Perspectives. Confirmations and statements should be retained as a record of your portfolio and its performance, and for future reference.

Trade Confirmations

Any time a transaction is executed on your behalf through Raymond James (with the exception of direct orders placed by you with mutual funds that issue their own communications), you will receive a trade confirmation notice. This is not a bill. Rather, it is a report to you of what transpired. If you access your account information online through Raymond James Investor Access, your confirmation will be posted with your account information the day the trade is executed. For those who receive hard copies of their confirmations, in most cases, we are able to mail the confirmation within 24 hours of the transaction; however, your receipt of it depends on the U.S. Postal Service’s delivery schedule. While it is rare that a client does not receive a confirmation, securities industry regulation requires payment for a purchase by settlement date. Your financial advisor will also receive a confirmation for every transaction executed on behalf of your account. The confirmation shows all the pertinent information regarding the specific transaction, generally including a complete description of the security, commissions, accrued interest (if applicable) and the total amount of money involved in the transaction. Raymond James’ confirmation is unique within the securities industry and will also advise you about your investment, including how it was executed and any risk factors that you should consider. In addition, it will provide such applicable information as yield to maturity, frequency of interest and/or dividend payments, accrued interest, and bond ratings and call dates. For managed account clients, we offer the ability to choose between receiving confirmations following each trade, monthly or quarterly by contacting your financial advisor. The combined trade confirmation report eliminates the need to review transactions as asset managers execute them. You can select your method of managed account reporting by contacting your financial advisor. It is important that you review and understand these notices, which are three-hole punched so you can easily keep them for future reference and tax purposes. Any inaccuracies or questions regarding your confirmation should be promptly directed to your financial advisor. If the issue is not addressed, please contact the branch manager or our international headquarters, as discussed under “Conflict Resolution.”

Account Statements

Client account statements, which include a complete, detailed report of your account, are mailed monthly if there has been activity in the account during that 30-day period. Quarterly statements are sent if there has been no activity during the previous 90-day period or if the account is an individual retirement account. Client statements are issued on a calendar month-end basis with the cut-off date being the last business day of the month. Statements are generally mailed within seven days of month-end. If you access your account information online through Raymond James Investor Access, your statement will be posted with your account information the day it would otherwise be mailed to you. In addition, Raymond James Elite Investment Account clients receive an annual summary “13th” month year-end statement summarizing all of their account activities for the previous year.” Your statement will show any securities (stocks, bonds, etc.) and cash or margin balances we are holding on your behalf, as well as any transactions (trades, dividends and interest, cash receipts and disbursements, securities receipts, or withdrawals) executed since your last statement. The brochure A Guide to Your Statement: An Indispensable Tool for Following the Progress of Your Investments, which you will receive with your first statement, will assist you in understanding how to read and evaluate your statement. For your convenience, you can link your accounts custodied at Raymond James & Associates so that you receive all of your account statements in one envelope under a comprehensive summary page. Each account will be reported in a separate column of the summary, providing you with an overall total allocation for all accounts on the summary page. All linked accounts will receive statements on a monthly basis. To link your accounts, please contact your financial advisor.

Composite Statement of 1099 Forms

The Composite Statement of 1099 Forms reflects your calendar year’s income required to be reported to the Internal Revenue Service. As an additional service, the composite statement includes information that Raymond James is not required to report to the IRS, but may be reportable by the taxpayer. You can expect your composite statement to accurately report your income as of our mailing date of January 31. You can also anticipate notification on your composite statement should you own a security that may require you to wait for additional information prior to filing your return. These forms should be retained for future reference.

If you owned certain mortgage investment conduit instruments during the tax year, it is possible that you may receive an additional 1099-OID or an additional detail statement mailed by March 15. Please contact your financial advisor for more information regarding the tax reporting requirements of mortgage investment conduit instruments.

In prior years, if you held mutual funds, you received a separate statement from the fund and from Raymond James. As explained in the section below, Raymond James is completing enhancements to make it possible to receive a consolidated 1099 statement, eliminating separate statements from each mutual fund. Certain broad-based index options may have differing tax treatment. You should consult with a qualified tax advisor.

Mutual Fund Consolidated Statements

Keeping track of mutual fund investments requires sorting through and studying separate statements sent by each fund you own. Then, to determine the total value of your investment, you must manually integrate the mutual fund information with our statement. We can incorporate your mutual fund activity into the one statement you already receive from us. Your mutual fund transactions and positions will be reported along with those of your stocks, bonds and other investments. Known as “networking,” this service is available for most funds. Networking is an automated communication system used to pass clients’ account information from participating mutual funds to brokerage firms. Through networking we are able to reflect all fund activity on your brokerage statement while shares are on deposit at the fund. All eligible mutual fund positions in your account will automatically be networked unless we receive written instructions from you specifically stating otherwise.

Since the needs of each client differ, networking was designed with four different levels. The amount of interaction you have with the fund depends on the networking level you choose. These levels determine who controls the fund account and whether you receive fund statements in addition to your brokerage firm statement. The following is a brief comparison of the levels:

For more information on networking, or to request your mutual funds be networked at a specific level, please contact your financial advisor.

 

Level 3

Level 4

Ability to deal directly with the fund

All dealings are with brokerage firm.

Can deal with brokerage firm or the fund.

Activity

No fund statements.

Activity reported on brokerage statements and statements from each fund.

SIPC insurance coverage

Covered.

Not covered.

Tax reporting

Responsibility of the brokerage firm. Consolidated 1099 for all your securities.

Primary responsibility of each fund.

NOTE: We have enhanced our computer systems to offer Level 3 Networking. In many cases, we can provide you with consolidated tax reporting for your mutual fund. These enhancements are in response to requests from our clients and financial advisors.

Your Choice of Accounts.

Because each of our financial advisors has the independence to address his or her clients’ individual needs, we offer a wide range of accounts, each with its own features for the transfer (sweeping) of funds. “Sweeps to and from interest-bearing accounts.” In addition, clients can choose to link their accounts so that they receive their statements in one envelope under a summary cover page that provides a convenient overview of all of their activity. Your financial advisor can provide details.

Important information about procedures for opening a new account

To fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account. As a result, when you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

Your Account is Protected.

Raymond James carries account protection equal to the amount of total net equity of securities held in custody for your account. The firm is a member of the Securities Investor Protection Corporation (SIPC), which protects securities customers of its members up to $500,000, including $100,000 in claims for cash awaiting investment (SIPC coverage). An explanatory brochure is available upon request or at sipc.org or by calling 202-371-8300. Excess protection is provided by Customer Asset Protection Company (CAPCO), a licensed Vermont insurer.

Account protection applies when a SIPC member firm fails financially and is unable to meet obligations to securities clients, but it does not protect against losses of value due to market fluctuations. While several large firms in our industry have chosen to limit levels of protection or, in some cases, not purchase insurance beyond the amounts covered by SIPC, Raymond James believes that increasing our coverage to cover the net equity of your account is consistent with our commitment to clients and will hopefully provide you with peace of mind concerning the safety of your account. For detailed information about SIPC, please ask your financial advisor for the brochure How SIPC Protects You.

It is important to note that balances and products such as certificates of deposit (CDs) held at Raymond James Bank, FSB are covered by the Federal Deposit Insurance Corporation (FDIC), subject to FDIC rules and aggregation limits, not by SIPC or excess SIPC. FDIC is an independent agency of the U.S. Government that insures bank held assets, up to a maximum of $100,000 per depositor ($250,000 for IRAs and certain other retirement accounts), including principal and accrued interest. For purposes of calculating the $100,000 limit ($250,000 for IRAs and certain other retirement accounts), you would aggregate any accounts, deposits and products you maintain in the same capacity directly with Raymond James Bank, FSB, with any accounts, deposits and products you maintain at Raymond James Bank, FSB through another intermediary such as Raymond James.

You are responsible for monitoring the total amount of such deposits at Raymond James Bank, FSB in order to determine the extent of insurance coverage available to you. Neither Raymond James nor any of its affiliates are responsible for any insured or uninsured portion of your deposits or CDs.

Further information on FDIC insurance can be obtained from your financial advisor, who will provide you with the FDIC brochure entitled Your Insured Deposits, FDIC’s Guide to Deposit Insurance Coverage upon request. You can also obtain information by contacting the FDIC, Division of Supervision and Consumer Protection, at Deposit Insurance Outreach, 550 17th Street N.W., Washington, DC, 20429. Their telephone number is 877-275-3342 or 800-925-4618 (TDD). You may also reach them at the FDIC Website at fdic.gov or by e-mail at dcainternet@fdic.gov. You may also wish to consult with your own attorney concerning FDIC coverage of deposits, particularly when held in more than one capacity.

Suitability requirements.

Not every client should own every investment. Because certain investments involve greater risk, clients very often must have a specific net worth or income before they can participate in those investments. The objective is to protect the investor as much as possible from the associated risk.

Investment objectives – low, medium or high risk tolerance – help to identify the investment goals for each of your accounts as part of a comprehensive financial plan. Your financial advisor will work with you to collect this information upon opening each account in order to gain a clear understanding of what your financial goals and needs are. In order for your financial advisor to make investment recommendations, he or she must gather certain information related to your financial status and investment history to ensure that your investments are designed to fit your individual circumstances. All of this information, along with your objectives, is compiled when filling out your New Account Form. You can find the investment objectives you selected on the front page of each of your statements.

Because your situation may change from time to time, it is necessary for you to review your goals with your financial advisor on an ongoing basis.

A better understanding of the investment objective definitions below will ensure that you are selecting the appropriate objectives for your unique situation.

Capital Preservation

Clients with this main objective seek to avoid loss of capital, even if it means achieving a lower overall long-term return. Investments consistent with this objective include traditional CDs, money market funds, insured high-grade municipal bonds and certain government bonds. This objective, by the nature of the investments, would entail a low risk tolerance.

Income

Clients with this primary objective focus on the receipt of dividends and interest. Corporate and municipal bonds, preferred securities, utility stocks, options covered call writing and fixed income mutual funds would be investments consistent with this objective. Risk tolerance can be low, medium or high, dependent on the credit quality and volatility of the securities selected for investment. For older or retired clients the risk tolerance should be considered low, except in unusual circumstances.

Growth

Clients with this objective seek investments designed to appreciate in price over a period of time. Investments in this category include equity mutual funds, stocks and other types of equity securities. Risk tolerance can be medium or high for this objective depending upon the client’s willingness and ability to tolerate losses.

Speculation

Clients willing to speculate risk significant loss of capital. Investments consistent with this objective include certain types of options trading, high-yield bonds and small or microcap equities. Speculation entails a high risk tolerance.

Online Access to Account Information.

Online access to account information is available free of charge to all clients. The service includes real-time account information, current trade confirmations and account statements, the ability to link accounts and quotes on a 20-minute delay basis. The service is password protected through Raymond James Investor Access with access arranged through your financial advisor.

Transferring Your Account to Raymond James.

Raymond James helps clients expedite the transfer of securities by offering advice and assistance, identifying the forms required by the appropriate transfer agents and facilitating the transfer of any security for legal or estate purposes. Clients are assured that their transactions are handled from start to finish as swiftly, efficiently and professionally as we can arrange. For details, please ask your financial advisor for a copy of our brochure Moving Your Portfolio to Raymond James.

The Patriot Act.

Under the USA Patriot Act, Raymond James is required to set up an anti-money laundering program, designate a special compliance officer, set up employee training, conduct independent audits, and establish policies and procedures to detect and report suspicious transactions and ensure compliance with the law. As part of our required program, we may ask you to provide various identification documents or other information in order to comply with this law. Until you provide the information or documents we need, we may not be able to open an account or effect any transactions for you.

Compensation to Transferring Financial Advisors.

Periodically, when a financial advisor transfers from one firm to another, he or she may receive compensation from his or her new firm. That “up front bonus” transition allowance or other incentive compensation is designed to offset the initial loss of income resulting from client accounts that may not choose to transfer to the new firm and for time spent re-establishing his or her practice at the new firm, as well as to induce financial advisors to change firms.

Privacy Notice

Raymond James, Heritage Distributors and the Heritage Family of Funds, administered by its wholly-owned subsidiary Heritage Asset Management, are committed to protecting confidentiality of the information furnished to us by our clients.

We are providing you this information as required by Regulation S-P adopted by the Securities and Exchange Commission.

Information About You That We Collect

We collect nonpublic personal information about you, including but not limited to, name, address, Social Security number and financial information from the following sources: information we receive from you on applications or other forms or through our website; information we receive about your transactions with us, our affiliates or others; and information we may receive from a consumer reporting agency.

Our Use of Information About You

As permitted by law, we may share information about you with other companies that are owned by Raymond James Financial. That information may include information shared by the Heritage Family of Funds with Raymond James broker/dealers and investment advisors, and information shared among other Raymond James service providers, such as financial advisors and insurance and annuity consultants. In addition, we may share information about you with certain nonaffiliated third parties, including service providers (e.g., mutual fund companies), non-financial companies (e.g., software developers), and others (e.g., consulting firms) in order to help us run our business, manage your accounts, provide professional services, or help us market our products and services to you. We may also share information about you with other financial institutions with which we have joint marketing agreements. These financial institutions have agreed to treat any such information as confidential and not share such information with any other parties except as permitted by law or regulation. Otherwise, we do not disclose any nonpublic personal information about you to anyone except as permitted by law or regulation. You also may have other protections under applicable state laws. To the extent these state laws apply, we will comply with them when we share information about you. We follow the same policy with respect to nonpublic personal information received from all clients and former clients.

When Financial Advisors Leave Raymond James

Financial advisors may change brokerage and/or investment advisory firms and nonpublic personal information collected by your financial advisor may be received or taken by your financial advisor to the new firm so that he or she can continue to service your account(s) at the new firm. If you do not want your financial advisor to utilize and/or transfer this information to another firm, please contact 800-647-SERV (7378) to opt-out of this information sharing. If your primary address is in an “opt-in” state (such as California and Vermont), which requires your affirmative consent to share your nonpublic information with the financial advisor’s new firm, then you must give your written consent before Raymond James will allow your financial advisor to take your nonpublic information with him or her. You can withdraw your consent at any time by contacting 800-647-SERV (7378).

Additional Information for Clients of the Financial Institution Division of Raymond James Financial Services

The Financial Institution Division of Raymond James Financial Services, Inc. is a party to joint marketing arrangements with certain banks and credit unions where you obtain Raymond James’ services. Information about clients who participate in these programs may be shared with the participating bank or credit unions. These financial institutions have agreed to treat any such information as confidential and not to share such information with any other parties except as permitted by law or regulation. In addition, you may have other protections under applicable state laws. To the extent these state laws apply, we will comply with them when we share information about you.

How We Protect Your Confidential Information

Raymond James has policies that restrict access to nonpublic personal information about you to those employees, associates and others who have need for that information to help us run our business, manage your accounts, market or provide investment alternatives or services to you, or to employees, associates, and others who assist those who help us run our business, manage your accounts, or market or provide investment alternatives or services to you. Additionally, we maintain physical, electronic, contractual, and procedural safeguards to protect your nonpublic personal information.

Placing Trades

Once your trade is placed, we will do our best to execute the transaction at the best available price. Smaller trades are generally executed via automated systems at the best available price.

You can place a trade by contacting your financial advisor or his or her licensed service associate. Please be specific and carefully explain your instructions. Ask the person to whom you are speaking if he or she will read back your instructions for verification. Then, once you receive your report confirming your trade (online the same day or in hard copy within a few business days of the trade), read it carefully to ensure that your instructions were carried out. If they were not, please contact your financial advisor immediately.

Raymond James or your financial advisor may combine sale and purchase orders of securities held by them with similar orders being made simultaneously for other accounts if, in our reasonable judgment, such aggregation is likely to result in an overall economic benefit to the client based on an evaluation that the client will benefit from relatively better purchase or sale prices, lower commission expenses or beneficial timing of transactions, or a combination of these and other potential benefits. Such transactions may be made at slightly different prices, due to the volume of securities purchased or sold. In such event, the average price of all securities purchased or sold in such transactions may be determined and the client may receive the average transaction price.

An “average price” per share is reported when multiple executions were required to complete your order and is a calculated average of the prices of each individual execution. Details regarding the actual price of each execution are available upon request. Although multiple executions were necessary, no additional fees or commissions were charged.

We are committed to ensuring that you receive the best trade execution available in the marketplace at the time an order is received. Please consult your financial advisor for further details.

After-Hours Trading.

While certain securities can be traded through Raymond James after hours, from 4 p.m. to 9:30 a.m. Eastern Standard Time, investors may assume increased risk due to what may be larger than normal spreads. Before entering into after-hours trading, you are advised to consult with your financial advisor for a more complete understanding of the process, including risk factors.

Trade Date and Settlement Date.

The day on which your trade is executed is the “trade date,” while the day on which you must pay for a “buy” trade or on which you can expect to be paid for a “sell” trade is the “settlement date.” Securities regulations specify three business days from trade date to settlement date for most securities. This regulation – which our industry calls “T+3” – may not provide sufficient time for you to receive the confirmation of your transaction by regular mail and then to pay for a buy. You will need to either have funds on deposit with us or pay based on verbal confirmation of the trade. Approximately 90% of our clients keep cash balances on deposit with us in competitive interest-bearing accounts to settle trades automatically.

Online Trading.

Raymond James Investor Access provides financial advisors with the ability to offer their clients the opportunity to trade many investment alternatives online. Before trading online, it is important to understand how securities transactions are executed, particularly during times of volatile prices and high volume, when there may be delays.

Sweeps (Transfers) to and from Income-Producing Accounts

Keeping your cash working hard for you is an important goal. We offer alternatives to keep your cash earning income when it is not otherwise invested. If you are purchasing an investment, the automatic sweep feature allows the exact amount of the transaction to be transferred to your investment account on settlement date, thereby eliminating the inconvenience otherwise involved with delivering funds. If you are selling an investment, the proceeds are automatically deposited to your account by the day following settlement date, enabling you to begin earning income on those funds until they are reinvested. You should carefully consider the features and benefits of each of the available sweep options, including the applicable interest rate or estimated yield, before selecting one that is appropriate for your account.

One alternative is the Raymond James Bank Deposit Program (RJBDP). RJBDP is an interest-bearing money market deposit account (MMDA) – a type of savings deposit account. This account is established by Raymond James, as your agent and custodian, at Raymond James Bank, FSB, which is an affiliate of Raymond James. Cash in your Raymond James account is managed through one or more master accounts at the bank with Raymond James, acting as your agent, maintaining the records for your individual transactions and balances. Rather than receiving a certificate or passbook from Raymond James Bank, FSB, your Raymond James account statement will reflect the account balances and transactions in your MMDA account. Additionally, balances held in RJBDP are FDIC insured in accordance with FDIC rules and aggregation limits. (Please see “Your Account Is Protected”)

The Bank intends to use the cash balances in RJBDP for purposes of current and new businesses including lending activities and investments. The profitability on such loans and investments is generally measured by the difference between the interest rate paid on RJBDP and other costs of maintaining the account, and the interest rate or other income earned by the Bank on those loans and investments (the “spread”). The income the Bank may earn through its lending and investing activities is anticipated to be greater than the fees which Raymond James and its affiliates earn from its other sweep investment options. These deposits are anticipated to provide a stable source of funds for the Bank’s business activities.

Raymond James and Raymond James Bank have entered into an agreement governing the deposit program, which specifies the remuneration, not to exceed 40 basis points (0.4%), and the services to be provided, in connection with the deposit program. Further information about the agreement is available upon request. No charges, fees or commissions will be imposed on your Raymond James account as a result of RJBDP being your sweep option.

Another alternative is our Client Interest Program (CIP). CIP is a short-term alternative for funds that are awaiting investment. (Raymond James separates all CIP funds held for the exclusive benefit of clients, as required by the Securities and Exchange Commission). We typically place CIP funds in overnight repurchase agreements that are fully collateralized by U.S. Treasury securities. This arrangement gives you access to the funds in your CIP account at any time during our normal office hours and on a 24-hour basis if you have an Elite Investment Account with VISA® Platinum debit card. CIP balances are included in the coverage provided by SIPC and excess SIPC. (Please see “Your Account Is Protected”)

Also available are two money market mutual funds offered through our Heritage Family of Funds. The Heritage Cash Trust Money Market Fund and the Heritage Cash Trust Municipal Money Market Fund, a tax-free money market fund, are both rated AAAm by Standard & Poor’s and offer competitive rates of return and free checking. Investors in the funds can write an unlimited number of checks per month, with a minimum check amount of $100 per check. Clients with a balance less than $50 in their Heritage money market account may periodically have their balance transferred to a non-interest bearing cash position. If the account subsequently reaches $1,000 in available cash, the cash will be swept back to the applicable Heritage money market fund. The $50 balance transfer and $1,000 minimum policies do not apply to qualified retirement accounts. Yields available at unaffiliated money market funds may be higher than those provided by the Heritage Family of Funds at any given time.

Investment in the Heritage money market funds is neither guaranteed nor insured by the FDIC or any other government agency, although such investments are generally eligible for coverage provided by SIPC and excess SIPC. (Please see “Your Account Is Protected” on page 23.) While these funds seek to preserve the value of your investment at $1 per share, it is possible to lose money by investing in the funds. Investors should carefully consider the investment objectives, risks, charges and expenses of the Heritage money market funds before investing. The prospectus contains this and other information about these funds. The prospectus is available from your financial advisor and should be read carefully before investing.

Funds may also be automatically transferred to and from your investment account and an individually named account held directly at Raymond James Bank, FSB. This option is appropriate when a bank sweep alternative is desired with additional features such as check writing. The balances held in individual named accounts at the bank are also FDIC insured in accordance with FDIC rules and aggregation limits. (Please see “Your Account Is Protected”)

Cash
Alternative/ Feature

Raymond James Bank
Deposit Program (RJBDP)

Client Interest Program
(CIP)

Heritage Cash Trust
(HCT) Money Market Fund

Heritage Cash Trust
Municipal (HCTM) Money Market Fund

Raymond James Bank
with Check Writing

Description

Omnibus bank money market deposit account1

Interest bearing brokerage cash account – cash awaiting investment

AAAm-rated taxable money market mutual fund invested in a variety of high-quality money market instruments that mature or reset in 397 days or less

AAAm-rated federally tax-exempt money market mutual fund invested in a variety of high-quality municipal securities with remaining maturities of 397 days or less

Standard bank money market deposit account with check writing

Current Rate/Yield

See raymondjames.com/rates.htm

Rate/Yield Calculation Method and Frequency

Set by Raymond James Bank based on relevant competitive money market rates and various market factors. Rate set weekly.

Set by Raymond James & Associates based on relevant competitive money market rates and various market factors.Rate set weekly.

Based on yield of underlying investment less expenses of managing the fund. Yield calculated daily.

Based on yield of underlying investment less expenses of managing the fund. Yield calculated daily.

Based on RJBDP rate minus percentage as determined by bank (“bank rate”). Rates set weekly.

Rate/Yield Tiers

No

Yes – For balances of $2500 or more: committee rate

$500 - $2499: committee rate less approximately 1.5%

$0 -$499: 0%3

No; however, $1,000 required to establish (minimum waived for ERISA and IRA accounts)

No; however, $1,000 required to establish (not available for ERISA and IRA accounts)

Yes – For balances of $25,000 or more: bank rate $1,000 - $24,999: bank rate minus approximately 1% $0 - $999: bank rate minus approximately 2%

Insurance Type

FDIC

SIPC and excess SIPC

SIPC and excess SIPC

SIPC and excess SIPC

FDIC

Availability of Funds

Next Day

Same Day

Next Day

Next Day

Next Day

Check Writing Available

No

No, except in conjunction with Elite Investment Account

Yes, $100 per check minimum

Yes, $100 per check minimum

Yes, limited by regulation to three checks per month

Automated Clearing House (ACH) Available

Yes4

Yes

Yes

Yes

Yes3

More Information

See raymondjames.com/rates.htm

1 An omnibus account denotes that one or more master accounts are maintained at Raymond James Bank, FSB in the name of Raymond James & Associates, Inc. where all RJBDP client balances are aggregated. Raymond James & Associates, Inc., as agent and custodian, maintains the individual client record and balance information.

For access to your funds, please contact your financial advisor.

2 CIP balances in Elite Investment Accounts are paid the committee rate less approximately 1.5% on balances from $0 to $2,499.

3 Money market deposit accounts are limited by federal regulations to no more than six Automated Clearing House (ACH) withdrawals per month. Please note: The process of converting an existing Raymond James account from one sweep alternative to another sweep alternative may result in a loss of dividend/interest for a period of one to two days. The duration depends specifically on the existing sweep option and the new alternative selected.

The Benefits of Street Name Accounts.

By having securities held in “street name” through Raymond James & Associates, your recordkeeping can be simplified and your responsibility to deliver sold securities eliminated. Additionally, all dividends and interest payments are made directly to Raymond James & Associates and promptly credited to your account for reinvestment or your personal use, while the proceeds of sales are promptly and automatically credited to your account.

All securities held in street name by Raymond James, along with all activities related to those securities, are reported on your Raymond James client statement. Added conveniences include the ability to make one address change to Raymond James rather than notifying separate transfer agents for each security, ease in transferring securities to heirs by completing a single copy of the required documents and access to the loan potential of your eligible portfolio through our Ready Access Account margin program.

Crediting Checks to an Account.

All checks – except cashier’s checks, traveler’s checks and money orders – deposited with Raymond James are subject to a minimum two-day hold. Certain checks, based upon size, account history and other factors, may be held up to 10 business days. Credit card or line of credit checks are subject to a 20 business day hold. With the exception of foreign checks, all checks begin to earn interest after two business days. Foreign checks, including those from Canadian banks, are not accepted for payment of a trade and are not credited to a client’s account until funds are received by Raymond James & Associates. This may take one to six weeks. Please always make your checks payable to Raymond James & Associates and include your account number. Financial advisors are required to have clients make checks payable to the firm. Do not make checks payable to a financial advisor or any other entity, as we cannot be responsible for these funds.

Quick Access to Your Dividends and Interest Payments.

While dividend and interest payments are credited to client accounts on the declared payment date, clients do have choices as to how they receive those payments.

Currently, many clients choose to receive dividend and interest payments by check or direct deposit to their bank accounts through the Automated Clearing House. Most prefer to have the payments automatically sweep into an interest-bearing account such as our Client Interest Program, Elite Investment Account, Raymond James Bank, FSB savings or checking account, or one of the Heritage money market funds. (Please see “Sweeps (transfers) to and from interest-bearing accounts.”)

Sweeping funds eliminates the need to cash checks or deliver them to another institution for deposit. It also eliminates possible delays due to “holds” placed on the funds when the checks are deposited in another institution and delays due to the postal service.

In addition, by sweeping, clients begin earning competitive rates of interest on their payments immediately.

Each interest and dividend payment and subsequent sweep is also automatically reported on the client’s account statement.

While funds are immediately available when credited, checks are processed and mailed by Raymond James each Friday. Those checks include all dividend and interest payments credited to an account during the previous week and are sent if total payments exceed $100 or they will accumulate in the client’s account until the $100 threshold is reached, at which time a check will be issued. Clients who receive dividend and interest payments by check will receive a breakdown of the payments included on each check.

Your financial advisor can assist you in selecting the best method for you to access your interest and dividends.

The Dividend Reinvestment Alternative.

For investors who would like to automatically buy additional shares of the underlying stock with each cash dividend, we offer a dividend reinvestment program. The option is available on most equity and closed-end fund shares traded on the New York Stock Exchange, the American Stock Exchange or the National Market System of the NASDAQ.

The program is offered free of charge on an unlimited number of securities in Elite Investment Accounts and any retirement plan accounts serviced by our Retirement Plan Services Department. It is also available for a fee in our Regular Investment Accounts.

In addition to the benefits of street name accounts cited above, such as consolidation of assets, estate simplification and loan eligibility, street name dividend reinvestment offers ease of liquidation of all full and fractional shares with one simple instruction to your financial advisor. No lengthy and cumbersome interaction with various agents is required.

Your Rights as a Shareholder.

Through investments in individual stocks and mutual funds you become a shareholder, or an owner in a business with a voice in how that business is run. As a shareholder you have the right to all financial reports issued by that company as well as the right to vote – either in person or by proxy – and speak at the annual meeting. You also have the right to call the company at any time to ask questions. Whether you hold the certificates or we keep them for you in “street name,” you maintain the same rights.

The Pitfalls of Penny Stocks.

As a rule, we will not execute purchases for stocks under $2 per share, unless that stock is traded on a major stock exchange or the NASDAQ system. Our reason is simple. In almost all cases, adequate financial information is available on stocks that trade on an exchange or NASDAQ, facilitating analysis of the security prior to purchase. Stocks that are trading under $2 per share and are not listed on an exchange or NASDAQ generally are riskier, as the companies are smaller and do not necessarily have the same reporting requirements as listed stocks.

Understanding the OTC Market.

The volume of orders in over-the-counter stocks has increased dramatically as most U.S. securities trade in that market. However, not understanding some basics of the OTC market can cause problems for investors.

Because most of these are smaller companies, their market capitalizations are generally smaller and the stocks are less liquid, creating a larger spread between the stock’s bid and ask prices. Furthermore, it will take longer to get pricing reports, as market makers often only make 100-share markets before changing their bid and ask. As a result, even a market order at a market opening might take a long time to execute at a series of prices, which would not happen in a large company stock listed on an exchange.

The information in this section also appears in the brochure entitled: “Your rights and responsibilities as a Raymond James client.”

 

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Raymond James & Associates, Inc. member New York Stock Exchange / SIPC and Raymond James Financial Services, Inc. member FINRA / SIPC are subsidiaries of Raymond James Financial, Inc.