RiverFront primarily uses RiverFront ETFs (ETFs that are sub-advised by RiverFront) in the RiverShares™ portfolios unless there is no RiverFront ETF that is consistent with the desired allocation or portfolio strategy. To the extent an appropriate RiverFront ETF is not available, RiverFront will select from ETFs managed by third parties. As a result, RiverShares portfolios typically include RiverFront ETFs notwithstanding the fact that there may be a similar third-party ETF with a higher rating, lower fees and expenses, or substantially better performance. Additionally, RiverFront will indirectly benefit from investments in RiverFront ETFs within the RiverShares portfolios through fees paid by the RiverFront ETFs to RiverFront for advisory (and other) services. RiverFront is thus subject to conflicts of interest in selecting RiverFront ETFs for the RiverShares portfolios. In addition, because the fees payable to RiverFront by some of the RiverFront ETFs may be higher than the fees payable by other RiverFront ETFs, RiverFront has a conflict of interest when choosing the RiverFront ETFs that pay higher fees to RiverFront. However, RiverFront has adopted policies and procedures designed to prevent these conflicts of interest from adversely impacting a RiverShares portfolio or any RiverShares ETF. In each case where a RiverFront ETF is selected for incorporation in a model portfolio, RiverFront has determined that each specific RiverFront ETF to be used is an appropriate security to implement the applicable model portfolio strategy.
RiverFront does not earn an account-level fee, including from a Sponsor Firm, with respect to accounts that employ a RiverShares model portfolio, in an effort to prevent a client from paying more than once for the investment advice provided by RiverFront. Clients who access RiverShares portfolios through a Sponsor Firm, however, will typically pay fees to the Sponsor Firm. Clients should speak to their Financial Advisor for more information on such fees, as they may vary among Sponsor Firms.
RiverFront Sub-Advised ETFs could be considered “start-up” or early stage funds with low assets under management. RiverFront has discretionary control of a significant amount of RiverFront client assets invested in its Sub-Advised ETFs. Withdrawing RiverFront client assets from the Sub-Advised ETFs could disadvantage the Funds and, as a result, other investors in the Funds, including other RiverFront clients.
RiverFront Sub-Advised ETFs are sub-advised by RiverFront Investment Group, LLC (“RiverFront”) and advised by either ALPS Advisors, Inc. (“ALPS”) or First Trust Advisors, L.P. (“First Trust”). Exchange-traded funds (ETFs) are sold by prospectus. For more information on the investment objectives, principle risks, and fees associated with these Funds, please see each Fund’s prospectus and statement of additional information (SAI), which are available on the Advisors’ websites at alpsfunds.com and ftportfolios.com.
ALPS Portfolio Solutions Distributor, Inc. (ADI), a FINRA member, is the distributor for the following ETFs: RIGS, RFCI, RFDA, and RFFC. ALPS Advisors, Inc. (ALPS) is the investment adviser to RIGS, RFCI, RFDA, and RFFC, and RiverFront Investment Group, LLC, is the investment sub-adviser. ALPS is not affiliated with RiverFront Investment Group, LLC. First Trust Portfolios L.P. is the distributor of RFDI, RFEU, and RFEM. First Trust Advisors L.P. is the adviser to RFDI, RFEU, and RFEM, and RiverFront Investment Group, LLC, is the investment sub-adviser. First Trust is not affiliated with RiverFront Investment Group, LLC or ADI or ALPS.
The Funds are distributed by ADI, 1290 Broadway, Suite 1000, Denver, CO 80203. ALPS is the investment adviser to the Funds and RiverFront Investment Group, LLC is the investment sub-adviser. ALPS is not affiliated with RiverFront Investment Group, LLC.
RiverFront Investment Group, LLC (“RiverFront”), is a registered investment adviser with the Securities and Exchange Commission. Registration as an investment adviser does not imply any level of skill or expertise. RiverFront is affiliated with Robert W. Baird & Co. Incorporated (“Baird”), member FINRA/SIPC, from its minority ownership interest in RiverFront. RiverFront is owned primarily by its employees through RiverFront Investment Holding Group, LLC, the holding company for RiverFront. Baird Financial Corporation (BFC) is a minority owner of RiverFront Investment Holding Group, LLC and therefore an indirect owner of RiverFront. BFC is the parent company of Robert W. Baird & Co. Incorporated, a registered broker/dealer and investment adviser.