UNDERSTANDING HOW JANNEY AND YOUR FINANCIAL CONSULTANT ARE COMPENSATED

Janney and our Financial Consultants receive compensation when clients invest in mutual funds. Depending on share class, compensation may be a front-end sales charge, a payment from a fund company, or a fee if mutual funds are purchased in a Janney fee-based account. In addition, Janney may receive a 12b-1 fee from mutual fund companies. Your Janney Financial Consultant may receive a portion of this compensation. This compensation is explained in the prospectus of each mutual fund. You should read the appropriate prospectus completely before investing in any mutual fund and discuss, with your Financial Consultant, the form of compensation she or he receives.

Educational Payments

As of June 23, 2005, Janney has established an Education Program which is funded by contributions from outside investment companies, including mutual fund firms. The policy governing the administration of the Education Program provides that:

• contributions shall not be tied to any form of additional compensation to our Financial Consultants
• contributions will not be used to promote any product or service of an outside investment firm
• the size of the contributions shall not be tied to the level of business between Janney and the investment firm making the contribution.

These contributions will be used to fund seminars (including associated expenses) with target audiences to include Janney clients, the general public, some of whom may be potential Janney clients and employees of Janney. The goal of the educational seminars will be to enhance financial education in general.

Networking Reimbursements

To defray the cost of sending confirmations, statements and tax reporting, Janney receives networking reimbursements from certain mutual funds. These range from $3.00 – $10.00 per client account per year, paid quarterly. Our Financial Consultants are not required to recommend these funds, nor do they directly share in any of the reimbursements.

For the year ending December 31, 2007, Janney received networking reimbursement from forty-five mutual fund companies. Listed in declining order of reimbursement amount, these companies are:

• American Funds
• Franklin Templeton Investor Services
• Oppenheimer Funds
• Federated Securities Corp.
• Putnam Investments
• Eaton Vance Funds
• John Hancock Signature Services, Inc.
• Hartford Funds
• Lord Abbett Family of Funds
• AIM Investments
• Alliance Bernstein Investor Services
• Massachusetts Financial Services Company
• Henderson Global Investments
• DWS Scudder Inc.
• Davis Selected Advisers, LP
• Delaware Service Company Inc.
• Columbia Management
• Allianz Global Investor Fund Management LLC
• Evergreen Funds
• Thornburg Investment Management
• Van Kampen Investor Services
• Prudential Funds
• Fidelity Corporate Services
• Pioneer Investment Management USA Inc.
• Dreyfus Service Corp
• Munder Funds
• Ivy Funds
• ING Funds
• AIG SunAmerica Asset Management
• Goldman Sachs and Co.
• Sentinel Administrative Services Inc.
• Seligman Data Corp.
• JP Morgan Worldwide Securities Services
• Nuveen Investments LLC
• Northtrack Funds
• Mainstay Funds
• Idex Mutual Funds
• Security Management Company
• Blackrock Distriburtors Inc.
• Phoenix Investment Partners
• Calvert Asset Management Co.
• Touchstone Investments
• Fred Alger and Co.
• Hotchkis & Wiley Funds
• Aquila Funds
• Heritage Funds
• American Century Investments
• Riversource Funds

Money Market Funds

Janney offers our clients a series of money market mutual funds which are managed by Dreyfus Funds. Janney and our Financial Consultants receive payments from Dreyfus in the form of 12b-1 fees and other marketing support payments. For further information, please request a prospectus on any of the Dreyfus money market funds we offer.

In addition to payments noted above, Janney receives commissions as compensation for executing trades generated through our institutional sales activities which are not tied or related to the products and services or to the related compensation (as described above) we receive from mutual fund companies. 

For additional information on mutual funds you may click on any of the web sites listed below.

http://www.sec.gov/ Securities and Exchange Commission

http://www.ici.org/ Investment Company Institute

http://www.sia.com/ Securities Industry Association

http://www.nasd.org/ National Association Securities Dealers