- Fees and Compensation and Item 12 - Brokerage Practices for more information.
14.C. Event Sponsorship
Periodically Sanctuary holds advisor meetings or industry conferences which may be firm-only or include external
attendees. These meetings provide sponsorship opportunities for vendors and other third-party providers. Sponsorship
fees allow these companies access to SA, LLC IARs and employees to discuss ideas, products, or services. The
sponsorship fees also supplement the payment of the meeting or future meetings. This presents a potential conflict of
interest, as SA, LLC may refer business to a certain vendor following their attendance and sponsorship. To mitigate the
potential conflict of interest, sponsorship fees are not dependent on assets placed with any specific provider, or the
revenue generated by asset placement. Event Sponsors may or may not be members of the Strategic Alliance Program
described below.
14.D. Strategic Alliance Program
Sanctuary Wealth receives compensation from certain product sponsors and unaffiliated investment advisors that
sponsor, manage and/or promote the sale of certain products that are available to our clients. Product sponsors and
third-party money managers (“Strategic Partners”) pay this compensation to Sanctuary Wealth in what we call our
Strategic Alliance Program (the “Program”). The Program includes product partner tiers which differ in both costs to
participate and the benefits received.
Strategic Partners are provided with more opportunities than other non-Strategic Partner companies to market and
educate our professionals on investments and the products they offer. The compensation arrangements vary and are
generally structured as a fixed dollar amount. You do not pay more to purchase Strategic Partner products through
Sanctuary Wealth than you would pay to purchase them elsewhere. In some instances, Sanctuary Wealth has negotiated
more favorable pricing for products offered by its Strategic Partners. Additionally, revenue sharing payments are not paid
to or directed to your IAR. Nevertheless, a conflict of interest exists, in that Sanctuary Wealth receives an economic
benefit when you purchase products from its Strategic Partners. This conflict is mitigated by the fact that IARs do not
receive any additional compensation for selling Strategic Partner products and are not required to recommend products
offered by Strategic Partners.
We use the revenue from our Strategic Partners to support certain marketing, training, and educational initiatives,
including our conferences and events. The conferences and training events provide a venue to communicate new
products and services to our registered representatives and IARs, to offer training to them and their support staff, and to
keep them abreast of regulatory requirements.
The benefits Strategic Partners receive may include but are not limited to:
• Information regarding the Sanctuary network of Partner Firms and training of sales personnel
• Promotion through our national conferences and regional road shows
• Comprehensive business mix intelligence on advisors and their sales growth
• Support from Sanctuary Investment Research
14.E. Other Cash and Non-Cash Compensation
In addition to reimbursement of training and educational meeting costs, our IARs may receive promotional items of
nominal value, meals or entertainment or other non-cash compensation from representatives of mutual fund companies,
insurance companies, third party money managers and other investment products, as permitted by regulatory rules.
14.F. Transition Assistance Benefits
When an IAR associates with SA, LLC after working with another financial services firm, the IAR can receive recruitment
or transition compensation from SA, LLC in connection with the transition. This transition assistance includes payments
that are intended to assist an IAR with certain defined costs associated with the transition; however, we do not verify that
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any payments made are used for transition costs. These payments can be in the form of repayable or compensatory
loans and are subject to favorable interest rate terms, as compared to other lenders. In the case of compensatory loans,
the loans are subject to repayment if an IAR leaves SA, LLC before a certain period of time.
Funds advanced by SA, LLC to an IAR under a compensatory loan are not taxable to the IAR when received but represent
taxable income as the principal and interest is forgiven by SA, LLC or the IAR is paid additional compensation to cover
the principal and interest on the note. Transition assistance payments can be used for a variety of purposes such as
providing working capital to assist in funding the IAR’s business, offsetting account transfer fees payable to the custodian
as a result of the clients transitioning to SA, LLC platforms, technology set-up fees, marketing, mailing and stationery
costs, registration and licensing fees, moving and office space expenses, staffing support, and termination fees
associated with moving accounts.
The amount of recruitment compensation is often significant in relation to the overall revenue earned or compensation
received by an IAR at his or her prior firm. Such recruitment compensation is typically based on a percentage of the IAR's
business established at their prior firm, for example, a percentage of the revenue earned, or assets serviced at the prior
firm, or on the size of the assets that transition to Sanctuary Advisors.