When we provide you with a recommendation as your broker-dealer or act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the recommendations and investment advice we provide you. When we act as your investment adviser, we are a fiduciary. Here are some examples to help you understand what this means.

Proprietary Products: We (or our affiliates) will earn higher compensation when you invest in alternative investment products that we (or one of our affiliates) issue, manage, or sponsor. This creates an incentive for us to recommend those alternative investment products over others to earn greater compensation.

Third-Party Payments: We receive payments from third-party product sponsors and managers (or their affiliates) when we recommend or sell certain products to you, including 12b-1 fees on mutual funds (which we credit back to advisory clients, except for certain consulting arrangements), and system support or network fees (which we retain). Although we do not charge third-party managers for participating in our advisory programs, the managers can make payments to us for sales and marketing materials and training. This creates an incentive for us to recommend (or to invest your assets in) products of third parties that pay us over products of third parties that do not pay us, or pay us less. We also receive a fee from each deposit bank that participates in our cash sweep program.

Revenue Sharing: We receive payments from the sponsors of UITs and hedge funds on our platform. We therefore have an incentive to recommend that you choose UITs or hedge funds on our platform.

Principal Trading: We can act as a principal for transactions in your brokerage account, which means you buy or sell securities to or from us. We earn markups, markdowns, and dealer spreads on principal trades. We therefore have an incentive to execute your trades as principal instead of trading other market participants.

You can obtain additional information about our conflicts of interest in our Brokerage Relationship and Disclosure Guide, Advisory Brochure (Item 4 and Item 10) and Wrap Fee Brochure (Item 4 and Industry Affiliations).

OPPENHEIMER & CO.

Kalamazoo, MI 49008

Scott Edward Heidema

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