Massachusetts Disclosure

Important Information for Massachusetts Residents

The Massachusetts Securities Division has adopted amendments to the standard of conduct applicable to broker-dealers and Financial Professionals who make securities (as defined under Massachusetts state law) recommendations to residents of Massachusetts. The amendments, effective as of September 1, 2020, require (i) disclosure of material conflicts of interest; and (ii) Financial Professionals to make all reasonable efforts to avoid conflicts of interest, eliminate conflicts that cannot be reasonably avoided and mitigate conflicts that cannot reasonably be avoided or eliminated. In addition, Financial Professionals must make recommendations and provide investment advice without regard to the financial or any other interest of any party other than the client.

With regard to the products applicable to this Massachusetts standard of conduct, some conflicts disclosed in the Regulation Best Interest Disclosure have been eliminated or mitigated for purposes of conducting securities business in Massachusetts, including elimination of the following: (i) receipt of payments from third-parties that are in addition to the transaction-based payments received from these third-parties; (ii) qualification for certain clubs and award incentives tied to meeting sales targets, (iii) receipt of subsidization from third-parties for marketing efforts, and (iv) compensation in the form of cash compensation or other gifts or entertainment from vendors or product sponsors to assist with and defray the expenses associated with educational seminars and client events held by the Financial Professional and/or the branch office of Park Avenue Securities LLC.