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Conflicts of Interest

Our Relationship With Mutual Fund Companies, Insurance Companies and Other Product Sponsors

As representatives of an independent broker/dealer, First Allied financial advisors have the ability to build investment portfolios based on the specific needs and goals of each individual client. First Allied offers a wide variety of approved products and programs including stocks, bonds, options, mutual funds, annuities, life insurance, alternative investments, college savings plans, and asset management programs. Because there are hundreds of investment choices within this universe of approved products, First Allied's marketing resources are focused on a select group of companies (product sponsors listed below) that offer a broad spectrum of products and meet First Allied's due diligence criteria. The product sponsors have greater access to our advisors to market, train and educate them on their products and industry related topics with the intent to better serve their mutual clients.

It is important to know that although the product sponsors pay compensation to First Allied and/or its affiliates, clients do not pay more to purchase these products through First Allied than they would normally pay to purchase them through another broker/dealer. The payment of this additional compensation to First Allied by these product sponsors may pose a financial incentive for us to promote certain products over other products, although we believe that these arrangements do not compromise the advice your advisor provides to you.

First Allied is providing the following information to help you better understand the potential conflicts of interests regarding compensation that First Allied receives from certain product sponsors whose investments we offer to you.

The additional amounts that these product sponsors pay First Allied vary from one sponsor to another and from one product to another. These payments can be calculated the following ways:

  1. As a fixed annual or one-time amount,
  2. As a percentage of sales ranging from .5 percent to 1.5 percent (which would be from $5 to $150 on a $10,000 investment)
  3. As a percentage of our customers' asset invested in the products ranging to a maximum of .10 percent (which would be $10 on a $10,000 investment),
  4. As a combination of these. The product sponsors who make these payments and the formulas by which they compensate First Allied are subject to change going forward.

All of these above-referenced payments are in addition to the sales charges disclosed in the offering materials of the investments offered by the product sponsors, and those offering materials have additional information about these payments.

Companies that are not product sponsors may at times send First Allied payments in recognition of our sales and marketing efforts, and may have additional opportunities to provide marketing services to our advisors. In addition, both product sponsors and other companies may pay marketing allowances to First Allied in connection with the sale of certain products and for training and educational meetings for our advisors. Both product sponsors and other companies may also reimburse up to 100 percent of the cost of due diligence, training and education/joint marketing meetings for our advisors, as permitted by industry rules. Sales of any products by First Allied advisors may qualify them for additional cash and non-cash compensation that may include support for their business activities, attendance at seminars, conferences and entertainment. Additionally, some investments, whether they are issued by a product sponsor or not, may pay higher rates of compensation than others (for example, commissions on equities are usually greater than those on bonds, and private placement offerings generally carry higher commissions than investments in publicly traded securities).

First Allied product sponsors for 2008 are listed below in alphabetical order:

Advanced Equities, Inc.
AEI Real Estate Fund, LLC
Allianz Global Investors
Allianz Life Insurance
American Skandia/Prudential
Argus Realty Investors
AssetMark
AXA Equitable
CNL Real Estate
Cole Real Estate
Dividend Capital
Fixed Income Securities
Hartford
Hines Real Estate
ICON Capital Corporation
Inland Securities Corporation
ING North American Ins. Corp.
Jackson National
John Hancock
Lincoln Financial
Met Life Investors
Pacific Life Insurance Co.
Riversource Annuities
Superfund
Sun Life
Vanguard*
Waveland Securities
Wells Investment Securities, Inc. Dividend Capital
* Flat Fee Only

The material provided herein is for disclosure and informational purposes only and is neither a solicitation to invest nor an offer to buy or sell securities. Any such solicitation or offer will be made only after a review of an investor's personal financial situation and only in those jurisdictions where permitted by law and upon delivery of required documentation.

Investors should carefully consider the risks, charges and expenses of a mutual fund or variable annuity prior to investing. This and other important information can be found in the fund's prospectus or variable annuity sub-account prospectus. Contact your financial advisor for a copy and always read it carefully before investing.

VENTURE CAPITAL AND PRIVATE EQUITY INVESTMENTS ARE EXTREMELY SPECULATIVE, CARRY A HIGH DEGREE OF RISK AND ARE SUITABLE ONLY FOR SOPHISTICATED AND "ACCREDITED" INVESTORS WHO CAN TOLERATE THE LOSS OF THEIR ENTIRE INVESTMENT. PLEASE SPEAK WITH YOUR FINANCIAL CONSULTANT FOR MORE INFORMATION REGARDING THESE QUALIFICATIONS AND INVESTMENTS.

Traded and Non-traded Real Estate Investment Trusts (REITs) involve special risks, which include: limited liquidity and demand for real property, changes in law, tenant turnover and defaults, competition, casualty losses and possible use of leverage. Values fluctuate based on economic, environmental and other facts. An investment in real estate or REITs may not be suitable for all investors. There are no assurances that the investment objectives of any real estate program will be obtained.

For more information call: 800-336-8842

Advanced Equities Plaza, 655 West Broadway, 12th Floor • San Diego, CA 92101

© 2008 Advanced Equities, Inc. member FINRA/SIPC