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Mutual Funds Disclosure for PAS


Introduction

A mutual fund is a collection of securities owned by a group of investors and managed by a professional investment adviser. A mutual fund pools investors' money to invest in a portfolio of stocks, bonds, money markets or a combination of these asset classes. Because the fund typically holds many different types of securities within a particular asset class, it offers greater diversification than you could achieve on your own. Most mutual funds aim at a particular objective—whether immediate income, income and growth, or long-term growth.

Revenue/Marketing/Education/Training/ Allowance
Some mutual fund families pay Park Avenue Securities (PAS), Guardian's retail broker/dealer subsidiary, revenue/ marketing/education/ training for support of our Financial Representatives. Since this information may be an important consideration in your decision to purchase a particular mutual fund product, you should read more about these payments in each mutual fund prospectus and statement of additional information. PAS may receive annual compensation of up to 0.25 percent on sales and .0275 percent on assets held at the mutual fund family. For example, if you held $10,000 with a participating mutual fund family for one year PAS could receive up to $27.75.

It is important to note that PAS Financial Representatives do not receive any portion of these fees which are separate from and in addition to other fees and charges applicable to each product.

Representatives of mutual fund families are subject to the discretion of Branch Office Managers, provided access to our branch offices and Financial Representatives for educational, marketing and other promotional efforts.

Although all fund families are provided with such access, some fund families devote more staff and resources to these activities and therefore may have enhanced opportunities to promote their funds to our Financial Representatives. This fact could, in turn, lead our Financial Representatives to focus on those funds when recommending mutual fund investments to our clients instead of on funds from those fund families that do not commit similar resources to education, marketing and other promotional efforts.

A listing of mutual fund families currently participating in this type of support is set forth below:

American FundsCompensation declared annually at the discretion of American Funds; typically, less that 0.01% annually based on assets under management for each calendar year
Fidelity Investments0.10% annually based on new sales for each calendar year
Oppenheimer0.0275% quarterly, based on the prior quarter’s assets under management
Other Expense Reimbursements: PAS and/or your Financial Representative may be reimbursed by mutual fund companies or their affiliates or other service providers for the expenses PAS and/or your Financial Representative may incur for various sales meetings, seminars, and conferences held in the normal course of business or for other services performed. Although mutual fund companies independently decide what they will spend on these activities, we are aware that some fund companies allocate their promotional budgets based upon prior sales and asset levels and that they work with our branch offices or Financial Advisors to plan promotional and educational activities on the basis of such budgets. We do not control mutual fund companies' determinations of how to allocate their promotional budgets or their spending decisions in this regard. Note that PAS policies establish procedures intended to ensure that the acceptance of the type of compensation described in this paragraph is carried out in conformity with applicable industry regulations. In particular, all proposed compensation of this type must be fully disclosed to, and approved in writing by, the PAS Compliance Department prior to acceptance.

FINRA rules prohibit Financial Representatives from receiving cash or non-cash compensation unless prior approval is obtained from the Financial Representative’s employing broker/dealer. Based upon this rule, no Financial Representative may accept cash or non-cash compensation from any product sponsor, unless express prior written approval is obtained from the PAS Compliance Department. The underlying premise of the rule involves guarding against influencing a Financial Representative to offer to a customer one particular product over another based on the opportunity to receive cash or non-cash compensation from a product sponsor.

RS Funds
RS Investments offers a comprehensive family of mutual funds for investors with a wide range of risk and reward profiles. These managed funds provide your clients with a wide array of tools for effective asset allocation.

Funds involve investment risks including possible loss of principal amount invested. Investment return and principal value of an investment will fluctuate and shares, when redeemed, may be worth more or less than their original cost.


Guardian Investor Services LLC (GIS), located at 7 Hanover Square, New York, NY 10004, (800) 221-3253 is the distributor of RS Funds, which are sold by prospectus only. The prospectus contains important information including fees and expenses. You should consider the fund's investment objectives, risk and charges and expenses carefully before investing or sending money. Please call 1¬800-766-FUNDS for a prospectus. GIS is an indirect wholly owned subsidiary of The Guardian Life Insurance Company of America, New York, NY.

Investments in RS Funds are not deposits obligations of, or guaranteed or endorsed by, any bank or depository institution, nor are they insured by the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Association (NCUA), the Federal Reserve Board, or any other agency. They involve investment risks including possible loss of principal amount invested. Investment return and principal value of an investment will fluctuate and shares, when redeemed, may be worth more or less than their original cost.

Securities products and services are offered through Park Avenue Securities LLC (PAS) and Guardian Investor Services LLC (GIS) located at 7 Hanover Square, New York, NY 10004. GIS and PAS are indirect wholly owned subsidiaries of The Guardian Life Insurance Company of America, New York, NY.