This page explains how compensation works, how potential conflicts of interest are identified and disclosed, and how they are managed. The purpose is transparency and informed decision-making.
Long-term advisory relationships require clarity not only about strategies and structures, but also about incentives.
Registration and Capacity
Investment services are provided in the capacity of a Mutual Fund Dealing Representative registered with WhiteHaven Securities Inc.
Insurance solutions are offered through appropriately licensed insurance distribution relationships.
All recommendations are made within the scope of applicable licenses, regulations, and professional standards.
How Investment Compensation Works
When a client invests in mutual funds, the fund manager charges a management fee. A portion of that fee is paid by the fund manager to the dealer, WhiteHaven Securities Inc., and a portion is paid by the dealer to the advisor.
This compensation:
- Is embedded in the fund's management fee
- Does not increase the cost of the investment to the client
- Is the same regardless of which licensed advisor is involved
Compensation is not based on trading activity or transaction volume. It is linked to assets held over time, which supports a long-term, stewardship-based approach rather than frequent changes.
How Insurance Compensation Works
When an insurance policy is issued, the insurance company pays a commission to the advisor.
Typically:
- A larger commission is paid at the time a policy is issued
- Smaller renewal commissions may be paid in subsequent years
- Renewal periods vary by product and insurer and are often, but not always, limited to a defined number of years
The cost of insurance is established by the insurer and does not change based on the advisor selected.
Conflicts of Interest : General Principles
A conflict of interest exists when an advisor's interests, including compensation, could reasonably be perceived to influence a recommendation.
Not all conflicts can be eliminated. They must be:
- Identified
- Disclosed clearly and in writing
- Managed in the client's best interest
This applies to both insurance and investment recommendations.
Insurance-Specific Conflict Disclosure
Insurance products involve commissions paid by insurers. As a result, a conflict of interest may arise because compensation varies by product, insurer, and structure.
When an insurance recommendation is made:
- Any material conflict of interest is disclosed in writing
- The purpose of the insurance, alternatives considered, and trade-offs are explained
- The recommendation is tied to a clearly defined planning objective, such as risk management, capital preservation, or estate strategies
If a conflict cannot be appropriately managed or disclosed, the recommendation is not made.
Investment-Related Conflict Disclosure (Voluntary)
Although investment compensation is embedded in fund fees and paid through the dealer, a potential conflict of interest may still exist, as compensation is linked to assets invested.
For this reason, the same disclosure standard is applied voluntarily to investment recommendations.
When an investment recommendation is made:
- The role of compensation is disclosed and discussed
- Recommendations are not based on incentives tied to trading or short-term activity
- Solutions are selected from multiple available providers rather than a single manufacturer
- The recommendation is documented in the context of the client's long-term strategy
This approach is intended to ensure consistency between insurance and investment advice and to support informed client consent.
Fees for Advice, Reviews, and Education
At this stage of the practice, no separate fees are charged for:
- Initial discovery conversations
- Educational or information sessions
- Periodic reviews
- Ongoing strategic discussions
These services are provided as part of an ongoing advisory relationship and are offered consistently to all clients.
The absence of a separate advisory fee does not reduce the depth, rigor, or responsibility applied to planning and recommendations.
If compensation structures or service models change in the future, such changes will be communicated clearly and in advance.
Brand-Agnostic and Structure-First Approach
No single bank, insurer, or investment provider is preferred by default.
Recommendations are made by:
- Defining the strategy and structural need first
- Evaluating multiple available solutions
- Selecting based on suitability, efficiency, and long-term fit
The objective is to isolate the best value for the specific strategy being implemented, not to promote a particular product or brand.
Ongoing Disclosure and Client Questions
Conflict disclosure is not a one-time event.
Clients are encouraged to ask questions at any time, and material conflicts are disclosed whenever recommendations are made or circumstances change.
Transparency is treated as an ongoing responsibility, not a compliance formality.
Important Disclosure
Investment and insurance solutions involve risk and may not be suitable for all clients. Past performance is not indicative of future results. Recommendations are based on information provided and may change if circumstances change.
For additional regulatory disclosures, please refer to the firm disclosure documents provided by WhiteHaven Securities Inc.
Why This Approach Is Intentional
Applying the same written conflict-of-interest discipline to both insurance and investments reflects a long-term, dynasty-building mindset. Consistency, documentation, and clarity protect not only the client, but the integrity of the planning process itself.
Last Updated: January 22, 2026