FIDELITY CLEARING & CUSTODY SOLUTIONS. Getting Future-Ready. Five Fundamentals to Growing and Transforming Your Business

Transcription

1 FIDELITY CLEARING & CUSTODY SOLUTIONS Strategy Talent Getting Future-Ready Five Fundamentals to Growing and Transforming Your Business

2 Getting Future-Ready Many of us have heard Wayne Gretzky s famous hockey quote, Skate to where the puck is going to be, not to where it has been. Now, more than ever, business leaders need to look ahead and anticipate the many trends that are reshaping the financial advice industry, to transform their firms for a new environment. From industry consolidation to disruptive technology to shifting investor demographics, we are seeing a myriad of change but change you can handle by taking steps to be a future-ready firm. Each year at Fidelity, we engage in many outreach activities with our clients to help them identify areas of strength in their business and opportunities for improvement. This has led us to identify what we believe are important elements to create a future-ready firm. These are the Five Fundamentals : Strategy, Talent, Technology & Operations, Risk & Regulatory, and Client Focus. Inside: Take Steps to Rev Up Your Business Strategy Talent Technology & Operations Risk & Regulatory Client Focus Be Prepared for Change This paper describes these Five Fundamentals in more detail, and asks important questions to help you assess whether your firm is prepared to take advantage of the new market realities. We have reached a seminal moment in the financial advice business when we need to get serious about planning for the future. Sanjiv Mirchandani, President, Fidelity Clearing & Custody Solutions 2

3 Take Steps to Rev Up Your Business THE FIVE FUNDAMENTALS OF A FUTURE-READY FIRM Strategy Create focus to capitalize on market opportunities by defining a clear strategy and business model for the long term Talent Develop a strong organization through the recruitment and cultivation of the right talent Technology & Operations Enhance the client experience and drive operational efficiency by harnessing technology effectively Risk & Regulatory Protect your business by managing changing regulatory requirements and mitigating risk Client Focus Drive growth by targeting the right clients with the right offering and modifying your approach as investor needs change Are You Ready for the Future Central to getting ready for the future is having a vision for what you want your business to look like down the road, along with a well-defined plan of action to help you get there. Ideally, this includes a written strategic plan that s updated regularly and shared with staff members to establish a set of common objectives. As important as a written document is, formal planning isn t a priority for many advisory firms. For example, less than half (49%) of RIAs participating in The 2015 Fidelity RIA Benchmarking Study 1 said they had a written strategic business plan. Developing a future-ready strategy should involve taking action across all Five Fundamentals. After all, it s hard to know what type of people you need if you haven t thought about your growth strategy, the technology that may be required if you haven t clearly defined your target market, or policies to put in place if you don t understand new regulatory requirements. Ask yourself, Are we a futureready firm Where should we focus our attention to move the business forward The sections that follow provide insights and considerations for each Fundamental. I don t know how an organization can maximize its potential and grow without a strategic plan that sets the direction and assigns responsibility for change. Bob Glovsky, Vice Chair & Principal, The Colony Group 1 The 2015 Fidelity RIA Benchmarking Study, Fidelity Clearing & Custody Solutions. 3

4 Strategy Create focus to capitalize on market opportunities by defining a clear strategy and business model for the long term The desire to increase scale, profitability, and growth prospects by joining forces with other firms is resulting in a rapidly consolidating market. This is creating a group of formidable competitors, calling for firms to rethink their business models to keep pace. Fidelity tracked 51 M&A transactions among wealth management firms in the first half of 2016, representing nearly $34 billion in assets under management (AUM). 2 In addition, the number of brokerdealer firms registered with FINRA dropped from 5,111 in 2005 to 3,957 in 2015 a 22% decline. 3 22% fewer broker-dealer firms registered with FINRA At the same time, the financial advice value chain is changing, and holistic financial planning is growing in importance as investment management becomes more commoditized. Yet, 44% of millionaires surveyed in a recent Fidelity study 4 who work with an advisor said they don t have a formal financial plan, and just over one quarter (29%) who do, said it was last updated over a year ago. Considerations to get future-ready: over a 10-year period Do you have a written succession plan that you are starting to implement A succession plan lays out how leadership and ownership will be transferred when partners of a firm decide to retire. While critical to help minimize any disruptions to clients, employees, and overall operations during periods of change, only 40% of participating firms in a Fidelity study 1 said they had a succession plan ready to put into action. Have you considered M&A as a way to propel your firm s business forward, and determined whether you ll play the role of a buyer or seller M&A transactions are gaining interest as firms look to expand their footprint, client base, and/or pool of talent. According to a Fidelity study, 5 66% of participating RIA firms said they would consider acquiring another firm in the next five years, and 40% said they would consider a merger. Despite this, buyers and sellers often aren t prepared to do a deal. Both groups may lack a concrete plan, have an unrealistic valuation in mind, or have failed to craft a compelling firm story to appeal to other advisors. More work may be needed to help execute successful transactions. We felt we were a great firm on our own, but could fundamentally be better if we came together with another great firm. Michael Nathanson, Chairman, CEO, and President, The Colony Group Is your offering strong enough to support your fee structure and attract investors as their needs continue to evolve More clients are looking to their advisor for guidance to help them reach their broader life goals, such as buying a home or saving for a child s education. 6 Many advisors recognize the need to adjust their offering in response. In fact, a Fidelity study 7 showed that 43% of participating advisors believe they ll have to provide more services, resources, and/or time to clients in order to maintain their current fee structure over the next one to two years. Planning for these changes will be imperative. 2 Fidelity 1H 2016 Wealth Management M&A Transaction Report, Fidelity Clearing & Custody Solutions. 3 How Small Broker-Dealers Can Survive in Today s Shifting Trading Landscape, TheStreet, The Fidelity 2016 Millionaire Outlook Study, Fidelity Clearing & Custody Solutions. 5 The 2014 Fidelity RIA Benchmarking Study, Fidelity Clearing & Custody Solutions; the study was conducted during the period May 6 through June 30, 2014, and the results included responses from 411 firms. 6 The 2016 Fidelity Millionaire Outlook Study, Fidelity Clearing & Custody Solutions. 7 The 2015 Fidelity Insights on Advice, Pricing Study, Fidelity Clearing & Custody Solutions. 4

5 TAKING STEPS TO GET FOCUSED Crestwood Advisors, an RIA headquartered in Boston, Massachusetts, had substantially increased its AUM since its launch in 2003, but the firm s leaders felt the team was running in too many directions. Management took a step back and asked who they should be serving given their core competencies. Strategy at Work at Crestwood Advisors LLC Here s an example of a firm that s sharpening its approach to Strategy: The team agreed that their ideal clients were first-generation entrepreneurs or businesspeople in their mid-forties to mid-fifties who were still in the wealth accumulation phase of their lives, and likely to have even greater liquidity down the road. These clients were also individuals who were interested in services beyond investment management to address a range of life events. The self-assessment enabled the team to focus their efforts in a much more thoughtful way. They began to build up their financial planning capabilities, and hired more Certified Financial Planner TM professionals. They also refined their solution set all the way from prospecting to ongoing communications to reporting. Importantly, they took the difficult step of backing away from clients who didn t match their profile. The result a more aligned and productive business. Crestwood Advisors LLC and the other firms featured in short case studies in this paper are independent and unaffiliated with Fidelity Investments. There is no form of legal partnership, agency, affiliation, or similar relationship among the firms and Fidelity Investments, nor are such relationships created or implied by the information herein. 5

6 Talent Develop a strong organization through the recruitment and cultivation of the right talent People are a firm s most valuable asset and, in the end, they ll determine business success. Making smart hires and taking steps to adequately develop and motivate staff members have become a priority. This is especially important given the estimated shortfall of 10,000 advisors by 2020, 8 as older advisors retire and fewer young people enter the profession. This impending imbalance also underscores the importance of improving scale and efficiency to help a smaller pool of advisors work smarter and faster. According to a Fidelity recruiting study, 9 some of the most attractive talent may come from outside financial services. By simply refining a job description, it may be possible to get the attention of candidates who are looking to solve problems, help people, or have a good work-life balance. 17% of college students say they are familiar with the financial advisor profession Recruiting Redefined: Perspectives on the looming advisor talent shortage, Fidelity Clearing & Custody Solutions, Considerations to get future-ready: Have you identified the type of skills you ll need to be future-ready, and how to find the most appropriate people to help your firm get there Good recruiting and hiring skills are needed to help get the right people on board to support a futureready business. With millennials projected to make up 50% of the workforce by 2020, 10 it will be important to understand how to appeal to this generation whose work habits, communications style, and expectations are different from those of baby boomers. 8 Cerulli Advisor Metrics Quantitative Update 2013, Cerulli Associates, and Envestnet estimates. 9 Recruiting Redefined, Perspectives on the looming advisor talent shortage, Fidelity Clearing & Custody Solutions, Three Reasons You Need to Adopt a Millennial Mindset Regardless of Your Age, Forbes, October The Fidelity 2013 Advisor Insights Study, Fidelity Clearing & Custody Solutions. 12 Findings Report, Journey to the Top: Insights on Developing and Retaining Future Leaders, Fidelity Clearing & Custody Solutions, Have you considered teaming to create a more productive work environment Teaming can often be an effective model to help round out technical competencies, transfer knowledge from senior to junior advisors, bring together different approaches and perspectives, and combine the skills of hunters and gatherers. A full 83% of advisors participating in a Fidelity study 11 agreed that they work better as a team than they could individually. In addition, 79% agreed that they were more likely to stay with their current firm because of their team. Do you have detailed job descriptions and a clear career development plan in place for each team member Talented people want to learn additional skills, gain experience, and take on more responsibilities over time. Fidelity research 12 shows that mentoring and spending time on development plans and regular performance reviews is something younger people, in particular, value and look for when vetting employment opportunities. Do you know where advisors may need training, and where you should spend your time and monies to enhance their skill sets Advisor segmentation and engagement can help you think about the capabilities, productivity levels, and strategic fit of your advisory team, to assess the type of support and development programs that may be required. This can also help you identify knowledge or experience gaps that may be filled as you recruit. Find good people, give them great opportunities, and fabulous things will happen. Adam Birenbaum, CEO, Buckingham Asset Management, LLC, and BAM Advisor Services LLC 6

7 Talent at Work at Securities America Here s an example of a firm that s sharpening its approach to Talent: Matching Younger Advisors with Younger Investors In 2014, Securities America, Inc., a large broker-dealer headquartered in La Vista, Nebraska, launched a program to train and mentor advisors under 40 years of age to specifically serve younger clients. As of mid-2015, this Next-Gen group represented about 20% of the firm s 2,000-plus advisor population. Securities America kicked off the initiative by forming a Next- Gen Advisory Council, to gather intelligence on how best to serve this segment of the market, and understand what development programs, marketing support, and technology to provide. The firm responded to the Council s suggestion to offer younger advisors more training, specifically through a special Next-Gen workshop and online tools. Securities America believes it s important to groom associates by having them shadow experienced advisors, and pair junior and senior advisors in a mentoring relationship. The firm also believes that Next-Gen investors value technology, including online collaboration tools, mobile applications, and real-time access to their accounts. Next-Gen advisors are encouraged to be as paperless as possible, and to establish a social media strategy that showcases the value they can bring to a relationship. The firm has also developed a series of marketing tools and client seminars to help advisors reach these younger investors. The end goal to be seen as a friendly place where Next-Gen advisors can grow their business. Securities America and the other firms featured in short case studies in this paper are independent and unaffiliated with Fidelity Investments. There is no form of legal partnership, agency, affiliation, or similar relationship among the firms and Fidelity Investments, nor are such relationships created or implied by the information herein. 7

8 Technology & Operations Enhance the client experience and drive operational efficiency by harnessing technology effectively Today, many firms think of their technology and operations infrastructure as a driving force for creating an exceptional advisor and client experience. And digital advice, which is expected to grow from $18.7 billion in AUM today to $489 billion by 2020, 13 is being seen by more traditional advisors as a complement to their services, if wisely employed % of millionaires surveyed expect technology to be part of how they manage their financial activities The 2016 Fidelity Millionaire Outlook Study, Fidelity Clearing & Custody Solutions A Fidelity study 15 identified a strong linkage between the use of technology and advisor success metrics. The study found that eadvisors participating advisors who engaged in more technology activities than their peers had almost 40% more AUM, attracted more Gen X/Y investors, and geographically expanded their reach. Of course, technology needs to be selected and implemented in a thoughtful fashion, and a technology strategy can help guide your decision making. Do you have plans to introduce esignature, edelivery, and mobile check deposit for your clients, and a document management repository for your advisors The paperless office is becoming a reality, and Fidelity research 18 shows that using online capabilities can help firms save time, support advisors working outside the office, enhance security, and offer a better client experience. According to McKinsey & Company, 19 document management systems alone may generate an improvement of more than 50% in productivity and customer service. The technology we have today lets us stay lean and manage a large number of relationships with few people. It also has many additional benefits for our clients. Jordan Smyth, Managing Director, Edgemoor Investment Advisors, Inc. Considerations to get future-ready: Is systems integration a priority for you to help reduce the duplication of tasks and have critical applications speak to one another A typical advisory firm uses six different types of software, 16 underscoring the importance of integration to improve the flow of information among numerous applications, such as customer relationship management (CRM) and financial planning systems. Have you been automating workflows using CRM and/or other systems to create efficiencies Workflows can help standardize tasks, streamline activities, and reduce costs. A combined workflow and document system, according to XTRAC Solutions, 17 may reduce operational expenses by up to 15% in just the first year of use. Have you taken steps to create a friendly and easyto-use client experience that includes a greater use of digital capabilities An enriched user experience incorporating online dashboards, collaboration tools, data aggregation software, and other features may help you attract and retain clients and advisors. This will be important to appeal to Gen Y investors, 20 75% of whom expect technology to be part of how their financial activities are managed, according to a Fidelity study Digital Advice to Hit $490 Billion by 2020, Cerulli Associates in Wealth Management.com, November The Rise of the Digital Advisor, InvestmentNews, December eadvisors Take the Lead, Fidelity Clearing & Custody Solutions, Adviser Technology Study, InvestmentNews, Workflow Cost Calculator, XTRAC Solutions, a Fidelity Investments company. Results are based solely on your input and are intended for estimating purposes only. Savings may vary. You should refer to your report for important details and limitations. 18 The Paperless Office Moves Forward, Five Steps that Can Help Drive Efficiency at Your Firm, Fidelity Clearing & Custody Solutions, Automating the bank s back office, McKinsey & Company, July Born between 1978 and The 2016 Fidelity Investor Insights Study, Fidelity Clearing & Custody Solutions. 8

9 Technology & Operations at Work at Truepoint Wealth Counsel Here s an example of a firm that s sharpening its approach to Technology & Operations: Integration, Automated Workflows, and Power Users The team at Truepoint Wealth Counsel, a large RIA based in Cincinnati, Ohio, is always looking for new ways to improve efficiencies and take the client experience to a higher level. Three overarching principles guide the firm s technology strategy: integrated systems, expert users, and automated workflows. The team members believe that system integration is critical for both efficiency and a seamless client experience. They replaced their technology with a suite of software that deeply integrates portfolio management, performance reporting, billing, rebalancing, and trading with an online client portal and an enterprise-level CRM system. They also believe that expert users are needed in order to take full advantage of the different applications. When they centralized investment management a number of years ago for advisors to spend more time with clients, they created a small group who became specialists in using Truepoint s portfolio management and rebalancing software. They have since centralized financial, estate, and tax planning. Again, this has put specific applications in the hands of a few people who can use them more regularly and fully. Finally, they believe that you need to adopt uniform workflows and processes if activities are to be streamlined and handled consistently across functions, and have automated workflows in your CRM system. The results significantly improved productivity across the firm and a better experience for clients. Truepoint Wealth Counsel and the other firms featured in short case studies in this paper are independent and unaffiliated with Fidelity Investments. There is no form of legal partnership, agency, affiliation, or similar relationship among the firms and Fidelity Investments, nor are such relationships created or implied by the information herein. 9

10 Risk & Regulatory Protect your business by managing changing regulatory requirements and mitigating risk Firms need to be well aware of possible vulnerabilities that could negatively impact the business, and how to stay compliant within a changing regulatory landscape. For example, much attention has recently been focused on the U. S. Department of Labor (DOL) investment advice rule, which may call for some firms to invest millions in technology and training to meet the rule s requirements % of advisory firms have increased monies spent on risk and compliance in the last five years. The 2015 Fidelity Risk and Compliance Study, Fidelity Clearing & Custody Solutions Risk and regulatory issues of potential concern are very broad, and even include how best to handle the decline in a client s cognitive ability, especially given the number of baby boomer investors who are aging. The Alzheimer s Association estimates that people over 65 afflicted by the disease could potentially triple to 13.8 million by 2050, unless medical breakthroughs are developed. 23 Considerations to get future-ready: Have you taken steps to become informed and educated about cybersecurity and data protection Wire fraud, identity theft, and scams continue to grow in number and sophistication. After gaining access to an investor s personal information, cyber criminals can commit various types of fraud. 24 As of 2013, fraudulent money transfers in the securities industry had risen by more than 60% over a twoyear period, according to the Treasury Department s Financial Crimes Enforcement Network. 25 Data security is also a potential problem, and recent headlines are a stark reminder that all kinds of enterprises are vulnerable to these breaches. Do you feel confident in your ability to manage an unplanned event that adversely affects your management team s ability to carry on A continuity plan is your firm s blueprint for ensuring continued business operation should something happen unexpectedly to the owners. The intent is to provide a seamless path for the firm s assets to pass legally to a chosen entity or person if business is interrupted by the unexpected event. Without a plan in place, a short- or long-term disability or the sudden death of the owner may alter the course of a business. Have you taken the time to properly review and understand all the emerging industry exposures Business risks can come in different forms from errors and omissions to dishonest employees. It s important to have a governance process in place to stay informed and educated about the challenges you may face today, and take steps to help manage any surprises. You can t put a price on your reputation. However, you can put a plan in place to help protect it and your clients. Greg Dawe, Senior Director, Regional Security and Operations Technology, Fidelity Investments 22 Figuring Out Fiduciary, InvestmentNews, May The Alzheimer s Association, alz.org/facts/overview.asp. 24 One Step Ahead: Help Protect Your Firm and Clients from Cyber Fraud, Fidelity Clearing & Custody Solutions, Wire Fraud Is on the Rise, by Matthias Rieker, Wall Street Journal,

11 Risk & Regulatory at Work at Signator Investors Here s an example of a firm that s sharpening its approach to Risk & Regulatory: Getting Ready for the DOL Investment Advice Rule The impending DOL investment advice rule is going to have a significant impact on advisors, and Signator Investors has taken numerous steps to prepare for the change. Chris Maryanopolis, president of this Boston-based broker-dealer with more than 2,200 financial professionals, is a member of a company-wide team that includes the firm s greater John Hancock parent and its different lines of business. The team meets weekly to discuss how the DOL rule is likely to affect the company, and the steps that need to be taken now to ensure that all regulatory requirements are met when the rule takes effect in Industry events, webinars, and discussions with legal counsel have helped Signator management better understand some of the issues. For example, Maryanopolis sees the product lineup for retirement accounts narrowing. He also feels that the rollover business, in particular, will be heavily affected, since fees in 401(k) plans are often lower than those in rollover IRAs. He also expects to see a continued move from commission-based businesses to the fee-only model. Outreach to advisors has been key, including in-person and online presentations to help educate the field and answer a wide range of questions and concerns. In addition, the compliance staff has been beefed up and major technology investments are being made. The goal is to use new technology to automate the process as much as possible, help advisors compare different investment options easily, and capture details on how advisors get to a product recommendation. The firm also plans to have a digital advisor option at some point, to handle smaller accounts that may not be financially feasible for an advisor to support in a more traditional model. The result Signator is on track to handle the many issues that need to be addressed to meet the deadline for compliance. Signator Investors and the other firms featured in short case studies in this paper are independent and unaffiliated with Fidelity Investments. There is no form of legal partnership, agency, affiliation, or similar relationship among the firms and Fidelity Investments, nor are such relationships created or implied by the information herein. 11

12 Client Focus Drive growth by targeting the right clients with the right offering, and modifying your approach as investor needs change A younger, more diverse group of investors, including more female and non-caucasian investors, is poised to be tomorrow s millionaires, according to Fidelity research. 26 These investors will likely be looking for a different advisory experience from what their parents had, calling for new prospecting and client engagement practices to retain wealth as it transfers to the next generation. In fact, a PWC study 27 says just over half (51%) of children who inherit assets keep their parents advisor. $30T As investor profiles evolve, you may want to consider taking a close look at who you serve today and want to serve tomorrow, and aligning an engagement model to stay relevant and in demand. Considerations to get future-ready: The expected wealth transfer to Gen X/Y investors by The Greater Wealth Transfer, Accenture, Do you have a strong firm story that all staff members can articulate clearly and consistently Your firm story is a critical element in your marketing and business development arsenal, to help capture the attention of prospects and have you stand apart from the competition. Surprisingly, only 56% of participating firms in The 2014 Fidelity RIA Benchmarking Study believed their firm story was clearly defined and differentiated, and less than half agreed that their stories were tailored to their target clients needs. Do you have well-established marketing and business development practices in place Marketing and business development activities should be handled in a disciplined manner. This requires a sound action plan, assigned responsibilities, and a measurement system to help take your business to the next level. Yet, only 5% of participating firms in The 2014 Fidelity RIA Benchmarking Study said they felt that their marketing and business development capabilities were advanced. Do you understand the unique needs of different types of clients you may serve A segmentation exercise is the process of classifying a business into subsets, to better understand the different requirements of clients who often have varied demographic profiles, accumulated wealth, sentiments, and interests. It may also help you identify clients who may not be a good fit for your firm. You have to do things differently today to stay ahead of the curve and in front of the competition. Jerry Luff, Chief Operating Officer, BakerAvenue Asset Management Are your engagement practices well defined to serve existing clients and build relationships with new investor groups Your engagement model requires well-defined approaches for how you ll serve existing clients and reach new segments of the market. Participating advisors in The 2015 Fidelity RIA Benchmarking Study predicted that 20% of their AUM will transfer to the next generation in the coming 10 years, yet only 18% of firms were confident that they have a high level of interaction with their clients adult children. It will be important to consider steps to help keep this money in motion from going elsewhere. 26 The 2014 Fidelity Investor Insights Study, Fidelity Clearing & Custody Solutions. 27 Global Private Banking and Wealth Management Survey, PWC,

13 Client Focus at Work at Teak Tree Capital Management Here s an example of a firm that s sharpening its approach to Client Focus: Express What You Stand For The team members at Teak Tree Capital Management, an RIA located in Fort Worth, Texas, wanted the name of their advisory firm to create an emotional connection with clients, and represent the type of caring relationship they could expect to have when working with the firm. They collaborated with an external marketing agency that helped them zero in on a name that captured the soul of who they are. The agency s team interviewed each person to understand their approach to business, why clients worked with them, some of the big opportunities and challenges they faced, and their respective personalities. In the end, strength through working together inspired their name. Teak wood is known for its protective properties durability, longevity, and growth in adverse conditions. Building on the name, the team chose three major principles that form the essential value proposition: We exist to inform our clients, help them get organized, and motivate them to act. Their conversations with clients don t center on skills as savvy investors, but on how the firm takes care of them and their families. Teak Tree employees try to express this sense of caring in how they operate every day. For example, as a value-added offering, they hired a licensed master social worker with a specialization in geriatrics, who serves as a client care advocate. Her role is to help clients and their families connect with appropriate caregiving resources during a transitional time of life. The results a firm name and operating principles the team can proudly stand behind. Teak Tree Capital Management and the other firms featured in short case studies in this paper are independent and unaffiliated with Fidelity Investments. There is no form of legal partnership, agency, affiliation, or similar relationship among the firms and Fidelity Investments, nor are such relationships created or implied by the information herein. 13

14 Be Prepared for Change The Five Fundamentals discussed in this document capture some of the many aspects that are involved in running a successful wealth management firm, as numerous trends alter the course of the industry. As mentioned, while each Fundamental is important in its own right, being diligent on all five fronts can help position your business well for what s to come. Consider challenging yourself and your team to think about the changes we are seeing, and the steps you should take to navigate these shifts and potentially capitalize on the array of new opportunities that are opening up. Please contact your Fidelity representative for more information and resources on the Five Fundamentals and being a future-ready firm. 14

15 FIDELITY CLEARING & CUSTODY SOLUTIONS 200 Seaport Boulevard, Boston, MA Seaport Boulevard Boston, MA For investment professional or institutional investor use only. Not for distribution to the public as sales material in any form. The information contained herein is as of the date of its publication, is subject to change, and is general in nature. Such information is provided for informational purposes only and should not be considered legal, tax, or compliance advice. Fidelity does not provide legal, tax, or compliance advice. Fidelity cannot guarantee that such information is accurate, complete, or timely. Federal and state laws and regulations are complex and are subject to change. Laws of a specific state or laws that may be applicable to a particular situation may affect the applicability, accuracy, or completeness of this information. This information is not individualized, is not intended to serve as the primary or sole basis for your decisions, as there may be other factors you should consider, and may not be inclusive of everything that a firm should consider in this type of planning decision. Some of the concepts may not be applicable to all firms. Always consult an attorney, tax professional, or compliance advisor regarding your specific legal, tax, or regulatory situation. The third-party companies referenced herein are independent and unaffiliated with Fidelity Investments. There is no form of legal partnership, agency, affiliation, or similar relationship among the third-party service providers and Fidelity Investments, nor is such a relationship created or implied by the information herein. Third-party trademarks and service marks are the property of their respective owners. All other trademarks and service marks are the property of FMR LLC or its affiliated companies. Fidelity Clearing and Custody Solutions provides clearing, custody, and other brokerage services through National Financial Services LLC or Fidelity Brokerage Services LLC, Members NYSE, SIPC. Fidelity Clearing & Custody Solutions, 200 Seaport Boulevard, Boston, MA Fidelity Investments Institutional Services Company, Inc., 500 Salem Street, Smithfield, RI FMR LLC. All rights reserved