Purchasing mutual funds and 529 plans through Ameriprise Financial

Ameriprise Financial Services has agreements with more than 135 mutual fund firms, which allows us to offer clients a broad range of approximately 2,200 mutual funds. The financial advisor’s goal is to select appropriate investments that help clients achieve their financial goals. The following sections describe important information relating to the availability of mutual funds offered through Ameriprise Financial Services and factors that may influence the mutual funds financial advisors recommend.

Payments from product companies

Our affiliate American Enterprise Investment Services (AEIS) performs, for the benefit of Ameriprise Financial Services, its financial advisors and clients, certain services, including but not limited to, distribution, marketing, administration and shareholder servicing support, applicable product due diligence, training and education, and other support related functions such as trading systems, websites and mobile applications (collectively, “cost reimbursement services”).

AEIS receives a variety of payments for cost reimbursement services from products sponsored or managed by affiliated investment advisers and by non-proprietary product companies, which reimburse the costs of client beneficial services provided by Ameriprise Financial Services and/or AEIS. The most significant of these payments are reimbursement for marketing and sales support received from the product companies. If Ameriprise Financial Services and/or AEIS did not receive this compensation, Ameriprise Financial Services would likely charge higher fees or other charges to clients for the services provided.

Mutual fund and 529 plan cost reimbursement payments

Mutual fund and 529 plan cost reimbursement payments are received from certain mutual fund firms (described below as “Full Participation” firms) within the more than 135 mutual fund firms (“firms”) Ameriprise Financial Services offers.

The goal at Ameriprise is to offer a wide range of mutual funds using the following criteria:

• Product breadth and strong-performing funds
• Financial strength of the firm
• Cost reimbursement payments paid to our affiliate AEIS to support cost reimbursement services
• Ability to provide wholesaling and training to our financial advisors
• Tax benefits offered by individual states (specific to 529 plans)
• Overall quality of the 529 plan

Financial advisors may offer, and clients are free to choose, mutual funds from more than 135 mutual fund firms. However, certain aspects of the mutual fund program (“Program”) may create a conflict of interest or incentive if Ameriprise promotes, or financial advisors recommend, the mutual funds offered by a firm participating in the Program vs. mutual funds offered by nonparticipating firms. In addition, among firms participating in the Program, financial advisors generally have a greater incentive to offer mutual funds from full participation firms. As further described below, these conflicts and incentives may arise from the cost reimbursement support provided to our financial advisors by, as well as the payments Ameriprise receives from, firms participating in the Program, and with other relationships with firms, including Columbia Threadneedle Investments, in addition to other fund brands (the “Affiliated Columbia Funds”) – see the section titled “Affiliated mutual funds” below.

To be included in the Program, firms have agreed to pay Ameriprise a portion of the revenue generated from the sale and/or management of mutual fund shares. Full Participation firms make cost reimbursement payments at a higher level than firms with other financial relationships. Each year a client holds shares of a particular mutual fund, the mutual fund’s financial advisor or distributor may pay to Ameriprise an amount based on the value of the collective mutual fund shares held in clients’ accounts (asset-based payment). In addition, a mutual fund’s financial advisor or distributor may pay a fee to Ameriprise for cost reimbursement services provided for the mutual fund shares purchased during a given period (sales-based payment). As of January 2020, Ameriprise received an asset-based payment  (up to 0.20% per year for mutual funds and 0.185% per year for 529 Plans) on some or all of Ameriprise clients’ assets managed by the participating firms. Certain mutual fund share classes may pay Ameriprise more cost reimbursement. As a result, Ameriprise financial advisors may have an indirect incentive to sell such funds.

Ameriprise receives up to 0.42% of money fund deposits for its money market fund sweep program. The amount that AEIS receives may be reduced based on fee waivers that are imposed by the money market fund firm.

Specific cost reimbursements are detailed below. These arrangements vary between firms and may be subject to change or renegotiation at any time. If a firm ceases to make cost reimbursement payments, AEIS may remove the firm from the Program and may cease to offer mutual fund shares and/or the 529 plan(s).

Education, training, seminar reimbursement and noncash compensation

Full Participation firms provide Ameriprise financial advisors, and in some cases their clients, education, training and support services relating to the funds they offer. These firms may reimburse Ameriprise Financial Services and Ameriprise Financial Services may subsequently reimburse the financial advisors for client/prospect education events and financial advisor sales meetings, seminars and training events consistent with Ameriprise policies. Ameriprise Financial Services and the financial advisors may also receive nominal noncash benefits from time to time. As a result, Ameriprise financial advisors may have a greater familiarity with and an incentive to sell funds and 529 plans of Full Participation firms.

Full participation firms

Thirty firms fully participate in the Program. These fund firms include Allspring, American Century, Amundi Asset Management, BlackRock, BNY Mellon, Columbia Threadneedle, Delaware Investments, DWS Investments, Eaton Vance, Eventide, Federated Hermes, Fidelity, First Eagle, Franklin Templeton, Goldman Sachs, Hartford, Invesco, Janus Henderson, John Hancock, JP Morgan, Lord Abbett, NY Life MainStay, MFS, Natixis, Neuberger Berman, Nuveen, Principal, PGIM Investments, Virtus and Voya. These firms are “Full Participation” firms.

We offer 529 Plans from 20 firms. Of those firms, 15 are also Full Participation firms. These fund firms include American Century, BlackRock, Columbia Threadneedle, Fidelity, Franklin Templeton, Goldman Sachs, Hartford, Invesco, John Hancock, J.P. Morgan, MFS, Nuveen, Principal, Virtus and Voya. Each of these firms is referred to as a “full participation firm.”

Mutual fund and ETF recommended list (the “Starting Point List”)

Ameriprise financial advisors may make mutual fund recommendations based on a group of funds that appear on the Starting Point List. The Starting Point List is developed by the Ameriprise Investment Research Group (IRG). Approximately 2,200 mutual funds are eligible for inclusion on the Starting Point List, which includes all mutual funds available for sale at Ameriprise, including Full Participation firms in the Program described above. When two similar mutual funds are equally recommendable for inclusion on the Starting Point List, IRG generally recommends, and therefore prefers, the mutual fund from a Full Participation firm.

In developing the Starting Point List, the IRG applies a quantitative and qualitative evaluation process that includes an analysis of a fund’s returns, risk and expenses, the tenure of its portfolio managers and the consistency of its performance and style. Certain mutual funds that would have otherwise been included on the Starting Point List were excluded due to their high investment minimums or expenses. The funds on the Starting Point List are subject to change periodically; however, changes to the Starting Point List should not be the sole reason to prompt trading.

This Starting Point List is developed by evaluating the performance characteristics of each fund’s A-share class; the analysis is ultimately intended to apply at the mutual fund level. However, managed account clients may be unable to purchase a fund on the Starting Point List if that fund does not offer an advisory share class. In addition, the Starting Point List was developed using those funds currently available through SPS Advantage, SPS Advisor or Ameriprise® brokerage. As a result, clients may not be able to purchase a fund on the Starting Point List if that fund is not available through other managed account services in which the client invests.

AEIS receives payments for the cost-reimbursement services it provides to the Full Participation firms (including Columbia Management Investment Advisers (CMIA)) and to other funds available for sale through Ameriprise Financial Services. The amount of any fees AEIS receives from funds eligible for inclusion on the Starting Point List is not considered in the selection process for inclusion on the Starting Point List, and no fund pays AEIS to be on the Starting Point List. Clients may choose to follow the recommendations provided by the Ameriprise financial advisor or may select from any of the other funds offered through Ameriprise Financial Services, regardless of whether that fund appears on the Starting Point List.

Distribution support relationships

Ameriprise also has cost reimbursement arrangements with firms for distribution support services. These firms make cost reimbursement payments to AEIS of up to and 0.10% on assets for these services, which support the distribution of the fund’s shares and 529 plans by making them available on one or more of Ameriprise Financial Services platforms. These mutual fund firms do not provide marketing and sales support such as those provided by Full Participation firms to Ameriprise financial advisors.

Ameriprise Financial Services sells 529 plans from seven firms that do not pay cost reimbursement. Moreover, plans offered by these firms are available for sale to in-state residents only. Those firms are: American Funds, Ascensus, Invesco, MFS, Orion, Union Bank & Trust and Virtus. Certain 529 plans may pay AEIS a fee of up to 1% assets for net asset value rollovers.

The total amount received from these firms in 2023 was $14,137,571.The firms that paid more than $500,000 were:

• PIMCO Funds ($1,673,946)
• AB Global ($1,354,558)
• American Funds ($1,172,443)
• Guggenheim ($624,723)
• Calamos Funds ($628,694)
• Transamerica Funds ($($524,235)
• AMG Funds ($533,120)
• Victory Capital ($524,366)

The remaining firms paid amounts ranging from $1 to $491,447.

Other financial relationships

The mutual fund’s distributor or affiliate may also make payments to AEIS for networking and/or omnibus support and other client services and account maintenance activities.

AEIS and its affiliates may have other relationships with firms whose mutual funds Ameriprise Financial Services offers. These relationships may include affiliates of firms acting as a sub-adviser to CMIA, CMIA acting as a sub-adviser to a third-party firm, or affiliates of a firm managing an investment portfolio within another Ameriprise or affiliated product, such as a RiverSource variable annuity. Firms may use CMIA to manage an underlying investment option in products offered through the Program.

AEIS has a cost reimbursement agreement with BlackRock Advisors, LLC with respect to mutual fund positions held by Ameriprise Financial Services customers. BlackRock, Inc. owns more than 5% of the outstanding shares of Ameriprise Financial, Inc. stock.

Transaction charges

Ameriprise financial advisors pay charges on mutual fund sales, purchases and exchanges (“transaction charges”). Transaction charges are determined using a variety of factors such as: the type of transaction, processing methodology (e.g., online, telephone, systematic arrangements), account type (fee-based SPS Advantage account/transaction-based brokerage account), and advisor channel.

Ameriprise financial advisors pay the same mutual fund transaction rate for orders entered by phone for all mutual fund firms.

Affiliated mutual funds

AEIS and other affiliates provide certain administrative and transfer agent services to the Columbia Threadneedle Funds.

Ameriprise Financial Services may enter into strategic alliances with companies that offer products or services that Ameriprise Financial Services and its financial advisors do not sell. In some of those alliances, Ameriprise financial advisors may receive gifts and offers from the other companies. Ameriprise Financial Services and its affiliates generally receive more revenue from sales of affiliated mutual funds than from sales of other mutual funds. Employee compensation and operating goals at all levels of the company are tied to the company’s success. Certain employees may receive higher compensation and other benefits based, in part, on assets invested in affiliated mutual funds.

Financial planning tools

Ameriprise has developed a variety of tools and resources to help its financial advisors make recommendations and serve you better. Some, but not all, of the financial-planning software tools available for use by your financial advisor were developed by Ameriprise or unaffiliated third parties and may make it more convenient for your financial advisor to select proprietary products.