Compensation Paid to Wells Fargo Clearing Services, LLC in Connection With Distributions of Shares of Closed-End Funds
Wells Fargo Clearing Services, LLC’s (“WFCS”) does not act as underwriter for distributions of shares of closed-end funds. WFCS does, however, offer and sell interests in closed-end funds underwritten by its affiliate, Wells Fargo Securities, LLC (“WFS”), to those WFCS customers for whom the securities are suitable. WFS may act as either a lead underwriter or syndicate member in these offerings. WFCS provides assistance to WFS in connection with these underwritings.
WFCS will receive a selling concession, as described in the prospectus, with respect to all securities it sells to WFCS customers. A portion of the selling concession will be shared by WFCS with the FAs responsible for selling the securities.
WFCS will separately, and in addition to the selling concession, receive a payment from WFS as compensation for WFCS’s assistance. In the case of closed-end funds, WFS will share up to one half of its fee for managing the underwriting syndicate and one half of the structuring fee it receives from investment advisers of closed-end funds it underwrites. The amount of the management fee is not disclosed in the prospectus for the securities offered but, together with the selling concession and the underwriting fee, constitutes part of the “sales load.” The structuring fee typically is disclosed in the Underwriting Section of the prospectus. This assistance payment will be made by WFS to WFCS after completion of the offering. WFCS will not share any portion of the assistance payment with WFCS FAs. The combination of the selling concession and the assistance payment may incent WFCS to encourage FAs to recommend these securities over other securities.