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Regulation Best Interest Disclosure
Effective 6/30/2020

This guide summarizes important information concerning the scope and terms of the brokerage services we offer and details the material conflicts of interest that arise through our delivery of brokerage services to you. We encourage you to review this information carefully, along with any applicable account agreement(s) and disclosure documentation you may receive from us.

As you review this information, we would like to remind you that we are registered with the U.S. Securities and Exchange Commission (SEC) as a broker dealer and an investment adviser, providing both brokerage services and investment advisory services. Our brokerage services are the primary focus of this guide. For more information on our investment advisory services and how they differ from brokerage, please review the Customer and Client Relationship Summaries (or Forms CRS) available on the Important Disclosures page of our website at Our Forms CRS contain important information about the types of services we offer, both brokerage and investment advisory, along with general information related to compensation, conflicts of interest, disciplinary action and other reportable legal information. Please carefully review and consider the information in each section below.
Brokerage services ....................................................................... 1
Brokerage service models and products .......................................... 4
Brokerage fees and our compensation ............................................ 4
Conflicts of interest ....................................................................... 7
Additional resources ...................................................................... 10

When you establish a brokerage account with us, you have the ability to buy, sell and hold investments within your account. The primary brokerage service we provide is our trading capability. We execute purchases and sales on your behalf, and as directed by you. In a brokerage services relationship we can trade with you for our own account, for an affiliate or for another client, and we can earn a profit on those trades. The capacity in which we act is disclosed on your trade confirmation. However, we are not required to communicate it in advance, obtain your consent, or inform you of any profit earned on trades.

Cash Brokerage and Margin Brokerage Accounts
We provide brokerage services through either a cash brokerage account or margin brokerage account, based on your eligibility and selection. In a cash brokerage account, you must pay for your purchases in full at the time of purchase. In a margin brokerage account, you must eventually pay for your purchases in full, but you may borrow part of the purchase price from our clearing firm, First Clearing1. This is generally referred to as a "margin loan." The portion of the purchase price that is loaned to you is secured by securities in your account, also referred to as "collateral." You will incur interest costs as a result of your margin activity. While many securities are eligible to be used as collateral for a margin loan, some assets are not available for margin collateral purposes.
1 First Clearing is a tradename used by Wells Fargo Clearing Services, LLC.

Since a margin-enabled brokerage account has specific eligibility requirements, unique costs, and governing regulatory requirements, our default brokerage option is our cash brokerage account. You must execute a separate margin agreement before engaging in margin brokerage activity. Included with your margin agreement is a copy of the Margin Disclosure Statement. This statement contains important information you should understand and consider before establishing a margin brokerage relationship with us. For more information on our margin brokerage services, contact the financial professional who provides service to your account, or refer to our Margin Disclosure Statement available upon request.

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Brokerage Account Types
We offer many different brokerage account types including individual and joint accounts, custodial accounts, Delivery Versus Payment (DVP) accounts, estate and trust accounts, partnership accounts, individual retirement accounts and other types of retirement accounts as outlined in our account agreement(s). You should refer to our account agreement(s) for more information concerning available account types or speak with your financial professional.

Incidental Brokerage Services, Recommendations and Account Monitoring
Within your brokerage account, we may also provide other incidental services such as research reports, and recommendations to buy, sell, or hold assets. When we make a securities recommendation, investment strategy recommendation or recommendation to rollover assets from your Qualified Retirement Plan (QRP) to an Individual Retirement Account (IRA), the recommendation is made in our capacity as a broker-dealer unless otherwise stated at the time of the recommendation. Any such statement will be made orally to you. Moreover, when we act in a brokerage capacity, we do not agree to enter into a fiduciary relationship with you.

It is important for you to understand that when our registered representatives make a brokerage recommendation to you, we are obligated to ensure the recommendation is in your best interest, considering reasonably available alternatives, and based on your stated investment objective, risk tolerance, liquidity needs, time horizon, financial needs, tax status, and other financial information you provide us. You may accept or reject any recommendation. It is also your responsibility to monitor the investments in your brokerage account, and we encourage you to do so regularly. We do not provide on-going monitoring of your brokerage account. If you prefer ongoing monitoring of your account or investments, you should speak with a financial advisor about whether an advisory services relationship is more appropriate for you.

Please also consider that from time to time we may provide you with additional information and resources to assist you with managing your brokerage account. This may include but is not limited to educational resources, sales and marketing materials, performance reports, asset allocation guidance, and/or periodic brokerage account reviews. When we offer these services and information, we do so as a courtesy to you. These activities are not designed to monitor specific investment holdings in your brokerage account, they do not contain specific investment recommendations about investment holdings, and you should not consider them a recommendation to trade or hold any particular securities in your brokerage account. Upon your request, we will review such information and reports with you and may provide you with investment recommendations, but we are not under a specific obligation to do so.

Clearing Services
We have entered into an agreement with First Clearing (also referred to herein as "Clearing Agent") to carry your account and provide certain back office functions. We and First Clearing share responsibilities with respect to your account as set forth in the Designation of Responsibilities that was delivered to you upon opening of your account. Please refer to the Designation of Responsibilities for more information on how such responsibilities have been allocated between us.

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Understanding Risk
It is important for you to understand that all investment recommendations and activities involve risk, including the risk that you may lose your entire principal. Further, some investments involve more risk than other investments. Higher-risk investments may have the potential for higher returns but also for greater losses. The higher your "risk tolerance," meaning the amount of risk or loss you are willing and able to accept in order to achieve your investment goals, the more you may decide to invest in higher-risk investments offering the potential for greater returns. We align risk tolerances with investment needs to offer you different investment objectives from which to choose (see below). You should select the investment objective and risk tolerance best aligned with your brokerage account goals and needs.

Investment goals typically have different time horizons and different income and growth objectives. Generally, investment goals are on a spectrum, with "Income" investors typically holding the smallest percentage of higher- risk investments, followed by "Growth and Income" investors holding some higher-risk investments, and finally "Growth" investors holding a significant portion of their portfolio in higher-risk investments. Risk tolerance also varies and we measure it on a continuum that increases from "Conservative" to "Moderate" to "Aggressive," and finally "Trading and Speculation." Please see the chart below for details.
Investment Objective Investment Objective Description Risk
Risk Tolerance

Income portfolios emphasize current income with minimal consideration for capital appreciation and usually have less exposure to more volatile growth assets.




Conservative Income investors generally assume lower risk, but may still experience losses or have lower expected income returns.

Moderate Income investors are willing to accept a modest level of risk that may result in increased losses in exchange for the potential to receive modest income returns.

Aggressive Income investors seek a higher level of returns and are willing to accept a higher level of risk that may result in greater losses.

Growth & Income

Growth and Income portfolios emphasize a blend of current income and capital appreciation and usually have some exposure to more volatile growth assets.


Conservative Growth and Income investors generally assume a lower amount of risk, but may still experience losses or have lower expected returns.

Moderate Growth and Income investors are willing to accept a modest level of risk that may result in increased losses in exchange for the potential to receive modest returns.

Aggressive Growth and Income investors seek a higher level of returns and are willing to accept a higher level of risk that may result in greater losses.


Growth portfolios emphasize capital appreciation with minimal consideration for current income and usually have significant exposure to more volatile growth assets.


Conservative Growth investors generally assume a lower amount of risk, but may still experience increased losses or have lower expected growth returns.

Moderate Growth investors are willing to accept a modest level of risk that may result in significant losses in exchange for the potential to receive higher returns.

Aggressive Growth investors seek a higher level of returns and are willing to accept a high level of risk that may result in more significant losses.

Trading and Speculation

Trading and Speculation investors seek out a maximum return through a broad range of investment strategies which generally involve a high level of risk, including the potential for unlimited loss of investment capital.

Our recommendations are based in part on your risk tolerance and investment objective as outlined above. We encourage you to carefully consider your investment objective and risk tolerance before investing.

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Cash Sweep Program Feature
Our brokerage services include a Cash Sweep Program feature. This program permits you to earn a return on uninvested cash balances in your brokerage account by allowing cash balances to be automatically "swept" into a "Cash Sweep Vehicle," until such balances are otherwise required to satisfy obligations arising in your account. These Cash Sweep Vehicles include interest-bearing deposit accounts, and if permissible, money market mutual funds or such other sweep arrangements made available to you. You will receive additional information concerning the Cash Sweep Program in your account agreement(s). More information about the Cash Sweep Program can be found in the Cash Sweep Program Disclosure Statement available on the Important Disclosures page of our website at Please review that Disclosure Statement carefully.

Account Minimums and Activity Requirements
There is no minimum initial account balance required to open a brokerage account with us. However, if you either fail to fund your account or do not return account opening documents as required, your account may be closed. In addition, some types of brokerage accounts have minimum account activity requirements or minimum ongoing balance requirements that must be maintained, or your brokerage account will be closed. These requirements are detailed in the account agreement(s) you receive when you open your brokerage account.

You should also understand that our financial professionals may establish their own minimum account balance requirements for the brokerage accounts they service. For example, a registered representative may choose to service only those brokerage account clients who satisfy account-specific or total household asset conditions. Minimum asset requirements are disclosed to you orally by your financial professional.

Lafayette brokerage accounts are all full-service, with the exception of self-directed retirement accounts. We do not offer phone-based or "robo-advice" brokerage accounts. All trades are broker-assisted. Lafayette does not offer online self-service trade entry options.

We implemented a self-directed service model for all brokerage retirement accounts in mid-2017. This means that Lafayette does not provide recommendations or advice to brokerage retirement accounts. All decisions regarding purchases and sales in these accounts, continued holding of assets held prior to the start date of the self-directed retirement service model, decisions on the use and selection of any Cash Sweep vehicle in the account, and decision to have a brokerage account rather than an advisory (managed) account are exclusively at the direction of the customer.

Lafayette acts solely as an order-taker in non-managed (brokerage) retirement accounts, and a restricted range of products is available in these accounts. Lafayette does not offer self-directed retirement accounts any fixed income positions from our inventory, since such an offering would be deemed Lafayette's solicitation that the customer purchase a security from us.

The motivation for the self-directed retirement account business model was to be able to demonstrate that Lafayette is a completely neutral party to your transactions in these accounts. In this way, Lafayette can demonstrate that we cannot, consciously or unconsciously, put our interests ahead of yours in the selection or recommendation of brokerage retirement account investments.

If you would prefer to have continuous investment management of your retirement account, or your non-retirement account(s), you may want to speak with a Lafayette financial advisor about whether an advisory (managed account) relationship is more appropriate for you.

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It is important to consider that while a brokerage relationship can be a cost-effective way of investing your assets, it is not for everyone given the fees and costs involved. Such fees and costs, your goals, investment experience and ability to evaluate and take action regarding your investments should be compared with the services available to you under an advisory (managed account) agreement. A managed account relationship typically charges fees quarterly based upon the amount of assets you have in your account. The fees and costs set forth below are those related to brokerage accounts, not managed (advisory) accounts.

Transaction-Based Fees
You will pay transaction-based fees for trades you decide to enter into, such as buying and selling stocks, bonds, Exchange Traded Products (ETPs), mutual funds and other investment purchases and sales. These transaction-based fees are generally referred to as a "commission," "mark up," or "sales charge." Transaction-based fees are based on many factors, including, but not limited to:
• Underlying product selection
• Your brokerage service model and account type
• Size of your transaction and/or overall value of your account
• Frequency of your trade activity
• Available discounts and/or fee waivers

Account and Service Fees
You will pay fees for various operational services provided to you through your brokerage account. These fees are set at least annually and communicated to you through information included in your account statement and other notifications. These fees do not apply to all account types and may be waived under certain conditions.

You should understand that based on the brokerage service model you choose, the same or similar products, accounts and services may vary in the fees and costs charged to you. For more information concerning our administrative and service fees, please refer to our First Clearing Customer Fee Schedule available on the Important Disclosures page of our website at for fees in brokerage accounts

How We Are Compensated
We receive direct and indirect compensation in connection with your accounts. Direct compensation is taken directly from the affected account. Indirect compensation is compensation paid in ways other than directly from the account and may impact the value of the associated investments in your account. The sections below describe the compensation that we receive in connection with various investments that may be available to you. In many cases, the descriptions that follow refer to a prospectus or offering documents.

Commission Schedule for Fixed Income, Equity & Mutual Fund Products
This schedule below details the commission charged to you and received by us and your financial professional for trades in the various products set forth below in brokerage accounts.

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Treasury or Corporate Bond Trade in Retirement Account   $20
Equity Trade in Retirement Account   $20
Treasury, Corporate or Municipal Bond Trade in Other Accounts   Reasonable principal markup or $50
Equity Trade for market order less than 100 shares   $50 – Larger trades at rates based on size and complexity of the order
Mutual Funds - Load and No-Load Liquidation Fee   $14 per trade
No-Load Commission/ Transaction Fee   $25

Lafayette does not permit Options Trading. Thus costs for it are not discussed here.

Debt Securities
For debt securities, including preferred securities, we may apply a charge (i.e., markup) of a fair and reasonable percent of the amount of your secondary market transaction. This markup varies by maturity, and typically increases with the maturity and risk profile of the debt security. Your confirmation will state the exact markup on certain debt securities transactions with us, in the case that we have an offsetting transaction in the same security that we traded with a retail investor on the same day. Additionally, we may incur gains (or losses) on positions we hold in inventory in response to market movements or other events that impact the value of the securities we own.

Mutual Funds
We currently offer many mutual funds varying in share class structure and investment style. If you invest in mutual funds, we may receive direct and indirect compensation in connection with such mutual fund investments, as described below.

12b-1/Shareholder Service Fees
Annual 12b-1 fees, also known as trails, are paid by the fund and paid to us out of fund assets under a distribution and servicing arrangement to cover distribution expenses and sometimes shareholder service expenses that we may provide on the fund's behalf. Shareholder servicing fees are paid to respond to investor inquiries and provide investors with information about their investments. These fees are asset-based fees charged by the fund family. These fees range from 0.00% to 1.00%, but the majority of these fees are below 0.85%. These fees may be passed on to us and may in turn be passed on to your financial professional as a commission.

Front-end Sales Charge Fees/Contingent Deferred Sales Charges (CDSC)
Front-end sales charge fees may be charged and paid to us, including your financial professional, when you purchase a fund. The front-end sales charge is deducted from the initial investment on certain share classes. This charge normally ranges from 0.00% to 5.75%. Some purchases may qualify for a reduced front-end sales charge due to breakpoint discounts based on the amount of transaction and rights of accumulation. In addition, some purchases may qualify for a sales charge waiver based on the type of account, and/or certain qualifications within the account. You should contact your financial professional if you believe you are eligible for sales charge waivers. Lafayette typically does not recommend mutual funds with front-end sales charges.

CDSC is a charge you pay upon withdrawal of money from a fund prior to the end of the fund's CDSC period. CDSC charges range from 0.00% to 5.50%. CDSC periods can range from zero to seven years. This charge typically exists only on share classes that do not have a front-end sales charge. It is sometimes referred to as the back-end load. CDSCs are not charged when you purchase a fund. The fee charged will depend on the share class purchased by the investor. A CDSC is not passed on to your financial professional. You can find a description of the amount and payment frequency of all fees and expenses charged and paid by the fund in the fund's prospectus. Fees and expenses disclosed in the fund's prospectus are charged against the investment values of the fund. Please note that 12b-1s and similar fees or compensation received in connection with our affiliated funds are not received, or are rebated, on ERISA assets held in advisory but not brokerage accounts.

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Revenue Sharing
In addition to the sources of compensation mentioned above, Lafayette receives compensation from its clearing firm, First Clearing, based upon any money fund sweep balances that customers may choose to hold in their accounts. In mitigation of this conflict, the customer, not Lafayette, controls the amounts of uninvested funds in any brokerage account. Cash sweep programs permit customers to earn a small return on the idle cash balances in their accounts by automatically investing them into a cash sweep option. However, cash sweep programs should not be considered an alternative to securities investments in investment accounts. Additionally, customers always have the right to receive any balances in cash sweep programs upon request, subject to any open commitments in any of their accounts.

Lafayette also receives compensation based on customer margin balances. Interest is charged on customer margin account balances at a rate determined by Lafayette. Lafayette's cost of funds is based upon a reference rate determined by our clearing firm, First Clearing. We earn the difference between the interest rate charged to the customer and Lafayette's cost of funds. Lafayette's revenues from margin debit balances are not material.

Data Agreement
Lafayette does not have any data agreements or "soft dollar" agreements with mutual fund companies.

Lafayette does not offer annuities as a product.

Alternative Investments Information
Lafayette does not offer alternative investments as a product.

Unit Investment Trusts (UITs)
Our UITs consist of Equity and Fixed-Income UITs. We, along with your registered representative, are compensated in ways that vary depending on the type and terms of the UIT portfolio selected. The types of fees received by us are disclosed via the prospectus issued by the UIT provider. Your registered representative can provide you a copy of the most recent prospectus. The UIT provider deducts fees as compensation from the proceeds available for investments for marketing and distribution expenses, which may include compensating us as described in each UIT prospectus. Lafayette is unlikely to recommend UITs. Trades in UITs are likely to be unsolicited, and at the customer's direction. For this reason, we refer customers to the specific prospectus issued by the UIT provider if the customer is interested in that UIT.

Training and Education
Lafayette registered representatives are not compensated for training and education in cases where the objective of such compensation is to reimburse us for brokerage costs. Lafayette does not receive free or discounted research or other vendor products or services as a means to provide incentive for registered representatives to recommend the products and services of those vendors.

However, Lafayette registered representatives (and financial advisors) occasionally attend meetings or events held to educate financial professionals on product or market characteristics, business building ideas, successful sales and marketing techniques, suitability and other topics.

Likewise, from time to time, product providers will reimburse us for expenses incurred by individual registered representatives (or financial advisors) in connection with training and educational meetings, conferences, or seminars for financial professionals.

Although training and education compensation is not related to individual transactions or assets held in client accounts, it is important to understand that such training and education meetings provide the opportunity for Lafayette financial professionals to interact with product providers. Consequently, those product providers that interact with Lafayette financial professionals in such meetings, seminars or other events gain an opportunity to build relationships with us. These relationships could lead to sales of that particular company's products.

Lafayette registered reps receive promotional items (including those of nominal value, such as note pads or pens), meals or entertainment or other non-cash compensation from product providers. Lafayette registered representatives may not give or receive gifts or other non-cash compensation in excess of $100 per rolling calendar year where such payment, gift or gratuity is in relation to the business of the employer of the recipient of the payment, gift or gratuity.

Lafayette registered reps may receive occasional gifts of meals or tickets to sporting, theatrical or other entertainments, provided that "such gifts shall not be so frequent or so excessive as to raise any question of propriety", and are not "in relation to the business of the recipient's employer."

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Operational Fees
We receive compensation for various operational services provided to you through a brokerage account. Our fee schedule for these services is available under Important Disclosures on our website.

Trade Corrections
Lafayette requests and facilitates limited trade corrections without passing the costs for such corrections on to the customer.

Compensation for Termination of Services
Other than any contingent deferred sales charge for a fund (as described under the Mutual Funds section above, if applicable), IRA termination fees (when applicable), and account transfer (ACAT) fees, Lafayette does not receive any additional compensation in connection with the termination of its services. If you have questions or need additional copies of documents regarding fees, please contact your registered representative.

Brokerage – Excluded Advisory Assets
As described above, our brokerage services differ from our advisory services. However, in some instances we may allow an advisory client to trade what are referred to as "excluded assets" within their advisory services account. Excluded assets are not subject to our advisory program fees. Instead of our advisory fees, these excluded assets are subject to our standard brokerage charges when traded. Such assets are often referred to as "unsupervised" within the advisory relationship, and would not be included when calculating quarterly asset management fees based upon managed assets.

Conflicts of interest exist, either consciously or unconsciously, when we provide brokerage services to you. A conflict of interest is a situation in which we engage in a transaction or activity where our interest is adverse to your interest. The mere presence of a conflict of interest does not imply that harm to your interests will occur, but it is important that we acknowledge the presence of conflicts. Moreover, our regulatory obligations require that we establish, maintain, and enforce written policies and procedures reasonably designed to address conflicts of interest associated with our recommendations to you.

Our conflicts of interest are typically the result of compensation structures and other financial arrangements between us, our registered representatives, our clients and third parties. We offer a broad range of investment services and products and we receive various forms of compensation from our clients, affiliated and non-affiliated product providers and money managers, and other third parties as described above. Securities rules allow for us, our registered representatives, and our affiliates to earn compensation when we provide brokerage services to you. However, the compensation that we and our financial professionals receive from you varies based upon the product or service you purchase, which creates a financial incentive to recommend investment products and services that generate greater compensation to us.

We are committed to taking appropriate steps to identify, mitigate and avoid conflicts of interest to ensure we act in your best interest when providing brokerage recommendations to you. Below you will find additional information related to our conflicts of interest. This information is not intended to be an all-inclusive list of our conflicts, but generally describes those conflicts that are material to your brokerage relationship. In addition to this disclosure, conflicts of interest are disclosed to you in your account agreement(s) and disclosure documents, our product guides and other information we make available to you.

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Compensation We Receive From Clients

Transaction-based conflicts
In your brokerage account you pay certain fees (commissions and sales charges) in connection with the buying and selling of each investment product, including mutual funds, exchange traded funds, equity securities, and bonds. Where these fees apply, the more transactions you enter into, the more compensation that we and your registered representative receive. This compensation creates an incentive for us to recommend that you buy and sell, rather than hold, these investments. We also have an incentive to recommend that you purchase investment products that carry higher fees, instead of products that carry lower fees or no fees at all.

Markups and markdowns for principal transactions
When you buy or sell securities in a brokerage account, and in accordance with industry regulations, we may impose a markup (increase) or markdown (decrease) in the price of transactions we execute on a principal basis. We are compensated based upon the difference (markup) between the price you pay for securities purchased from us and the price we sell such securities to you over the prevailing market price, or the difference (markdown) between the price you sell securities to us and the price we purchase such securities from you over the prevailing market price. We maintain policies and procedures reasonably designed to help ensure compliance with the markup and markdown industry rules.

Account maintenance and other administrative fees
For the services we provide or make available to you with respect to your brokerage account, we charge certain account maintenance and other administrative fees, including transfer, wire, or other miscellaneous fees, as described in the fee schedule provided to you on an annual basis. The higher the fees we charge, the more we are compensated.

Compensation We Receive From Third Parties

Third-party payments we receive may be based on new sales of investment products, creating an incentive for us to recommend you buy and sell, rather than hold, investments. In other cases, these payments are made on an ongoing basis as a percentage of invested assets, creating an incentive for us to recommend that you buy and hold investments. Lafayette registered representatives do not receive material compensation from "trails", or from ongoing payments as a percentage of invested assets.

The total amount of payments we receive varies from product to product. Lafayette's registered representatives do not recommend third-party investment management products other than Lafayette's own investment advisory service. Some Lafayette brokerage customers also have advisory accounts serviced by Lafayette investment advisors, who are compensated as a percentage of assets under management by means of quarterly billings in advance. Lafayette's compensation varies, and includes the compensation we receive in connection with other products, and services we may make available to you, including advisory services. We have an incentive to recommend investment products and services that generate greater payments to us. This compensation generally represents an expense embedded in the investment products and services that is borne by investors, even where it is not paid by the Product Sponsor and not paid directly from the investment product or other fees you pay. The types of third-party compensation we receive include:

Revenue Sharing. Please refer to the section above regarding revenue sharing and money fund sweep balances.
Trail Compensation. We may receive ongoing compensation from Product Sponsors and shared such compensation with our registered representatives. This compensation (commonly known as trails, service fees or Rule 12b-1 fees in the case of mutual funds) is typically paid from the assets of the investment product under a distribution or servicing arrangement and is calculated as an annual percentage of invested assets. The amount of this compensation varies from product to product. We have an incentive to recommend that you purchase and hold interests in products that pay us higher trails. Lafayette does not receive material revenue from mutual fund trails.

Additional Compensation from Product Sponsors and Other Third Parties
We and our registered representatives, associates, employees, and agents receive additional compensation from Product Sponsors and other third parties including:

Gifts, an occasional dinner or ticket to a sporting event.

Reimbursement from vendors for technology-related costs, such as those to build systems, tools, and new features to aid in servicing clients.

Note: The amount of these payments is not dependent on or related to the level of assets you or any other of our clients invest in or with the Product Sponsor.

Product Share Classes
Some Product Sponsors offer multiple structures of the same product (e.g., mutual fund share classes) with each option having a unique expense structure, and some having lower costs to you as compared to others. We are incentivized to make available those share classes or other product structures that will generate the highest compensation to us. Lafayette brokerage associates do not typically recommend mutual funds as an asset class. Lafayette investment advisors rigorously select the mutual fund share classes most beneficial to investment advisory customers.

Payment for Order Flow
Lafayette's registered representatives do not receive payment for order flow.

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Compensation Related to Proprietary Products
Brokerage recommendations can include a recommendation to invest in a product or service that is managed, issued or sponsored by us or our affiliates. We and our affiliates will receive additional compensation or economic benefits from investments by you in such products, including, but not limited to, management credits, service fees and similar revenue sharing arrangements. The compensation related to these may be greater than similar products provided by third parties. Thus, we have an incentive to recommend investments in proprietary/affiliated products. Lafayette's only proprietary product is investment management.

Compensation Related to Our Affiliates

Lafayette's clearing firm receives compensation based upon balances in sweep funds, including their proprietary products.

Please see section below regarding compensation received by Lafayette's financial advisors under investment advisory agreements.

The Research We Provide
Lafayette's registered representatives provide product comparisons and asset valuations, but do not provide regularly-issued research products or mailings to all of our customers.

Compensation Received by Lafayette Investment Advisors

Lafayette's investment advisors (as opposed to brokerage registered representatives) are compensated based on the investment advisory fees charged to the account. For further discussion of our investment advisory services, please see ADD ADV Reference of Form CRS Advisory.

Both investment advisors and registered representatives have an incentive to recommend that you roll over assets from a Qualified Retirement Plan (QRP) to a brokerage Individual Retirement Account (IRA) because of the compensation they will receive. We maintain policies and procedures designed to ensure that rollover recommendations are in your best interest.

Investment advisory accounts feature an ongoing fee based on assets under management. Brokerage accounts do not charge such asset-based fees. Investment advisors are incentivized to recommend that you transition your brokerage services account to an advisory account to generate ongoing revenue where your brokerage account has minimal activity. We have established controls to identify and mitigate this risk.

Registered Representative Activities
Registered representatives may be motivated to place trades ahead of clients in order to receive more favorable prices than their clients. Lafayette has rigorous monthly trade reviews in place to detect and prevent this practice.

Registered representatives who are transitioning through a succession plan may be incentivized to make brokerage recommendations designed to increase the value of their "book of business" through asset accumulation or brokerage trades that are not in your best interest. Registered representatives who receive clients from a retiring registered representative are incentivized to meet growth goals and may make recommendations not in your best interest.

Internal campaigns and recognition efforts incentivize registered representatives to engage in activities to reach incentive goals. However, Lafayette does not permit sales contests or sales quotas, or bonuses or non-cash compensation that is based on the sale of specific securities over a specific period of time.

In mitigation of the above conflicts of interest, Lafayette has in place policies and procedures under Regulation Best Interest that require registered representatives to place the best interest of customers ahead of their own. They must have a basis for recommendations they make to customers which serves customers' best interests. Brokerage trade tickets of retail investors are expected to demonstrate the basis upon which a recommendation to a retail investor was made, and how such recommendation is consistent with the customer's best interest considering reasonably available alternatives, costs and the customer's goals.

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Title Web address or location of document

Lafayette's Customer and Client Relationship Summaries ("Form CRS"), First Clearing Cash Sweep Program and First Clearing Customer Fee Schedule
Margin Disclosure Provided with account opening paperwork, or upon request
Investment Objectives and Risk Tolerance Provided with account opening paperwork, or upon request

Lafayette Investments is registered with the Securities and Exchange Commission as an investment advisor and a broker-dealer.