Distribution Services
Something that we take great pride in
Through our affiliate PINE Distributors LLC, we can provide a suite of legal underwriter and related solutions to pooled investment vehicles including ETFs, mutual funds, and closed-end funds, as well as placement marketing support for private fund sponsors.
Our Distribution Services establish a solid foundation from which asset managers can deliver their product to market, while thoughtfully managing legal and compliance risks. Services available on a turn-key or tailored basis include:
Legal Underwriting Services
- Act as legal underwriter/statutory distributor
- Prepare initial and periodic 15c presentation to Fund/Trust Board
- Prepare reporting and attend Fund/Trust Board meetings, as requested
- Review Fund advertising and sales literature via an internet based portal designed specifically for marketing material review and retention.
- Provide registered principal approval for advertising and sales literature and file material with FINRA
- Prepare, update, execute & maintain financial intermediary agreements
- DTCC/NSCC membership and operations support
- ETF distribution solutions
- Provide Authorized Participant (“APs”) contact list and consultation
- Negotiate and execute agreements with APs
- Provide AP order taking call-center and toll-free number for Fund(s), if applicable
- Affirm AP create/redeem orders processed by custodian / index receipt agent
- Perform Rule 12b-1 fee administration and reporting
Registered Representative Services
- Maintain FINRA licenses and provide compliance oversight for Client’s employees (i.e., registered representatives or “RR”)
- Administer and ensure RR’s participate in FINRA’s Continuing Education Program
- Conduct annual compliance training for RR’s
- Review and approve advertising materials used by RR’s, which function may be conducted by the fund’s statutory distributor
- Manage RR’s registration status to ensure compliance with FINRA and state requirements
- Manage and process any RR compensation that is directly based on sales success
- Provide RR’s with Pine’s broker-dealer written supervisory procedures and provide periodic training
- Support and assist the Client’s designated on-site supervising principal, if applicable, with their supervisory responsibilities
*PINE Distributors, LLC is registered with the United States Securities and Exchange Commission as a broker-dealer and a member of FINRA. PINE Distributors (including its registered representatives) acts solely in a wholesaling capacity and does not offer advice, does not open or maintain shareholder accounts, does not custody shareholder funds for investment, and does not process shareholder purchase, redemption, or exchange orders.
ETF Solutions
Our experienced professionals stand ready to advise you regarding the regulatory, financial, operational and distribution requirements of your ETF’s. We closely follow the expanding U.S. and international ETF marketplaces and the rapid product innovation in the market today.
Registered Representative Licensing
PINE can assist with all aspects of your FINRA licensing needs for both registered and private funds.
Legal Underwriting and Placement Agent Services
Through our broker-dealer, PINE will serve as the legal underwriter for registered funds (mutual funds, closed-end funds, and ETFs) and placement agent for private funds.
Frequently Asked Questions
Through its limited purpose broker-dealer entity PINE Distributors LLC, PINE can provide a suite of legal underwriter and principal distributor solutions to mutual funds, closed-end funds, and ETFs, as well as placement marketing support for private fund sponsors.
PINE Distributors LLC is a limited purposed broker-dealer, as such the firm (including its registered representatives) acts solely in a wholesaling capacity and does not:
• offer investment advice
• open or maintain shareholder accounts
• custody shareholder funds for investment
• process shareholder purchase, redemption, or exchange orders
The PINE team will conduct an extensive review and facilitate discussions with an adviser and other service providers to a fund. Together we will identify the most appropriate range of services, including; named statutory distributor, registered representative licensing, advertising & sales content review, intermediary contract management & oversight, intermediary fee administration, and ETF solutions.
No - when PINE Distributors LLC provides distributions services to a fund, we act as the legal underwriter, also referred to as principal underwriter or distributor. To provide these services, PINE Distributors LLC will maintain its required registration as a broker dealer with the SEC under the Exchange Act, as well as its membership of FINRA.
While the adviser of a fund can recommend that PINE Distributors LLC acts as distributor, this is subject to review and a “15(c) approval” by the fund board of directors. PINE will provide full support for the review and approval process, including creating a detailed 15(c) response for board consideration.
Yes, employees of advisers to funds that PINE provides distribution services to may be registered representatives of PINE Distributors LLC. This is subject to individual qualification, as well as agreement to follow PINE Distributors written supervisory procedures and for a registered individual’s distribution related activities to be supervised by PINE Distributors.
In addition to standard Distribution Services, PINE can provide additional ETF-specific solutions such as an authorized participant agreement management process, and an authorized participant order desk.
Yes, PINE can provide customized services to most registered pooled-investment vehicles, including closed-end funds such as tender-off and interval funds.