We have adopted policies and procedures that we believe are reasonably designed to monitor and mitigate any conflict of interests.
A "Conflict of Interest" is something that might incline a person, consciously or unconsciously, to make a recommendation that
is not disinterested. We believe these policies allow us to monitor, mitigate and, if possible, eliminate conflicts that incentivize
your financial professional to prioritize their interests over yours. We want you to be able to understand any material facts or
Conflicts of Interest and make an informed decision
At USA Financial, we continually strive to avoid conflicts of interest where possible, and otherwise to manage them as effectively
as we can by first identifying the conflict and then by eliminating it, disclosing it, or mitigating it in some other way. We
have adopted a Conflict of Interest policy (and related policies and procedures) to identify, consider and manage potential conflicts
of interest and protect the integrity of our relationships with you and your affiliated representative.
For example, we do not have limitations on offerings, so your financial professional is not inclined to place their interests, or
the interests of the firm, ahead of a retail customer's interest. We have eliminated sales contests or other compensation based
on the sale of a specific security within a limited period of time. We have also has taken steps to avoid compensation thresholds
that disproportionately increase compensation through incremental increases in sale.
USA Financial Securities conducts its advisory business professionally and ethically, adhering at all times to relevant rules, laws,
and guidelines. Accordingly, pursuant to Rule 204A-1 of the Investment Advisers Act of 1940, we have adopted a Code of Ethics.
Copies will be provided upon request.
USA Financial Securities or its representatives may buy or sell securities for its or their own account(s) ("Proprietary Account(s)"),
securities that we recommend to our clients, including clients that are related persons. Neither our firm nor our related persons
are permitted to enter into, or have an interest in, an investment transaction that would create a conflict between our interests
and your interests without fully disclosing the conflict to affected clients. Similarly, neither our firm nor our related persons
are permitted to benefit, directly or indirectly, from transactions made fin your account. Proprietary Accounts may benefit on the
same basis and to the same extent as clients' accounts when each holds the same investment. We do not allow "cross transactions"
between clients or between clients and Proprietary Accounts.
Generally, investments may only be purchased for proprietary accounts simultaneously or after client purchases. Investments may
only be sold simultaneously or after client sell-orders are completed. Exceptions may be made for personal securities trades
that we believe do not involve potential conflicts of interest, such as open-ended mutual funds, U.S. Treasury securities,
and small amounts of stock or closed-end funds that have very large market capitalization and/or very high average trading volume.
A Conflicts of Interest associated with a recommendation is defined as an interest that might incline your broker, consciously or
unconsciously, to make a recommendation that is not disinterested. As we have disclosed in our Form CRS, conflicts of interest
arise when we sell proprietary product, when we receive payments from a third-party product sponsor, or when affiliated entities
share revenue with us. Our brokers have conflicts when they participate in our internal incentive programs or when they receive
non-cash compensation from securities issuers.
USA Financial has established a conflicts framework that incorporates an initial inventory of existing and potential conflicts;
an assessment of the conflict in terms of the Firm’s ability to eliminate or otherwise manage and mitigate the conflict
(including through disclosure); and finally, ongoing and periodic reviews of and for conflicts.
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