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Training and Compensation Policies

The following information is designed for current and prospective customers of First Investors Corporation (“FIC,” “we,” or “us”). FIC is a broker-dealer that serves as the principal underwriter of its own family of mutual funds and life insurance products. We have been in the business of helping investors since 1930. We still do business the old-fashioned way. Our representatives meet with clients in-person, generally in their homes or places of business, develop detailed profiles of their financial situations, investment experience, goals and tolerance for risk, and recommend investments and life insurance products that are suitable for them.

We train our representatives to advise our clients to take a long-term, diversified approach to investing, to avoid trying to time the market, and to refrain from selecting funds based upon recent performance alone. We believe that one of the most damaging mistakes most investors make is to base their investment decisions on short-term results. This has been confirmed by countless studies. As Dalbar, a respected financial research firm, stated in one of its studies, “[i]nvestment return is far more dependent on investor behavior than on fund performance. Mutual fund investors who hold their investments are more successful than those that time the market ….”

We also train our representatives and managers to recommend First Investors funds and products to our clients. We believe that our own family of funds and variable insurance products is sufficiently diverse to meet the investment needs of most of our clients. We also know more about our own products and have better supervisory control over them. Although we allow our representatives to sell some non-proprietary funds, we do so solely as an accommodation to representatives and to clients who wish to invest outside of our fund family. In most of our offices, non-proprietary funds represent a small percentage of fund business. Indeed, many of our representatives do very little business in non-proprietary funds.

We pay our representatives and managers more for selling First Investors funds than we do for selling non-proprietary funds. The compensation that a First Investors representative or manager earns on the sale of a particular product depends, of course, upon a variety of factors, including the type of product, the sales charge rate, whether a breakpoint or discount is available, the class of shares being sold, and the concession that is received by the dealer. Some of these differences exist on an industry-wide basis. For example, representatives generally earn more for sales of variable annuities and variable life products than they do for sales of mutual funds. However, all else being equal, our representatives and managers receive more compensation for selling First Investors funds than for selling outside funds. This is so because, in part, we pay them a higher percentage of the dealer concession on sales of First Investors funds than on sales of outside funds.

We have not attempted to equalize our pay-outs on inside and outside funds because, to do so, we would be required to ask for and receive revenue sharing payments (or so-called “shelf space” money) from outside fund groups. Revenue sharing payments are generally payments by fund sponsors to broker-dealers that have placed their funds on preferred or approved lists, and satisfied other criteria. These payments are in addition to the normal dealer compensation from sales charges and rule 12b-1 fees that are described in fund prospectuses. While many other broker-dealers have accepted revenue sharing payments for placing non-proprietary funds on their preferred lists, we have decided that the better approach is simply to focus on our own products.

We do not offer investment advisory services to our clients. Our business is limited to recommending and selling mutual funds and insurance products to our clients based on a careful analysis of their needs. Our clients have brokerage accounts with us, not advisory accounts. Any advice that we provide to our clients is solely incidental to the sale of securities and insurance products. We do not receive any compensation for our advice other than the commissions, dealer concessions, and rule 12b-1 fees that are described in fund prospectuses and other disclosure documents.

If you have any questions about our products and services, please feel free to contact your representative or call us at (800) 423-4026. For more information about our funds, you can also review our prospectuses and shareholder manual, which are available on this website. Please read the prospectus for any mutual fund before you invest in it. It will provide you with a description of the associated fees, charges, principal investment strategies, and principal investment risks. An investment in a mutual fund is not a bank deposit and is not insured or guaranteed by the Federal Deposit Insurance Corporation, any other governmental agency, or any bank.