Overview
- Headquarters
- Duluth, GA
- Average Client Assets
- $1.5 million
- Minimum Account Size
- $25,000
- SEC CRD Number
- 10111
Fee Structure
Primary Fee Schedule (PRIMERICA ADVISORS LIFETIME INVESTMENT PROGRAM)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.25% |
| $500,001 | $1,000,000 | 1.10% |
| $1,000,001 | $3,000,000 | 1.00% |
| $3,000,001 | $5,000,000 | 0.85% |
| $5,000,001 | $10,000,000 | 0.80% |
| $10,000,001 | $15,000,000 | 0.75% |
| $15,000,001 | $25,000,000 | 0.55% |
| $25,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,750 | 1.18% |
| $5 million | $48,750 | 0.98% |
| $10 million | $88,750 | 0.89% |
| $50 million | $306,250 | 0.61% |
| $100 million | $556,250 | 0.56% |
Clients
- HNW Share of Firm Assets
- 20.62%
- Total Client Accounts
- 89,813
- Discretionary Accounts
- 89,813
Services Offered
Services: Portfolio Management for Individuals
Regulatory Filings
Additional Brochure: PRIMERICA ADVISORS LIFETIME INVESTMENT PROGRAM (2026-03-20)
View Document Text
Wrap Fee
Program Brochure
Form ADV Part 2A
Appendix 1
March 30, 2026
This wrap fee program brochure provides information about the qualifications and business practices of Primerica
Advisors. If you have any questions about the content of this brochure, please contact us at (833) 786-0550. The
information in this brochure has not been approved by the United States Securities and Exchange Commission or by
any state securities authority.
Additional information about Primerica Advisors also is available on the SEC’s website at www.adviserinfo.sec.gov.
This brochure is updated annually and potentially more frequently. The most recent version is available at
Primerica.com/pfsidisclosures or adviserinfo.sec.gov.
1 Primerica Parkway, Duluth, GA 30099-0001
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Item 2 – Material Changes
Certain Models include allocations to exchange traded
funds that invest exclusively in cryptocurrency. If you
invest in one of these models, you will not directly own
any cryptocurrency. Rather, you will own shares of a fund
that invests in cryptocurrencies, such as Bitcoin, Ether
and others. Investments in cryptocurrency involve risk,
including:
Item 2 requires us to summarize material changes to
our Form ADV Part 2A Appendix 1 Wrap Fee Program
Brochure. Only material changes since the last annual
update of the brochure dated March 31, 2025, are
included below.
Item 4 – Fees. The discussion of fees has been updated
as follows. The fees you pay will not change except for the
Program fee reduction described below.
1. The chart showing the maximum annual wrap fee by
• Volatility: Cryptocurrency prices can be extremely
volatile and subject to wide price swings. As such,
funds that track
individual cryptocurrencies or
cryptocurrency indexes are likewise subject to high
levels of volatility;
tier has been removed.
2. The Advisory fee and Program fee schedules have
been updated so that the three highest tier levels, by
account value, have been combined to reduce the
total number of tiers from nine to seven.
3. Effective April 3, 2026, for accounts valued at
$3,000,000.01 and above, the Program fee will be
reduced as follows:
• Diversification and Correlation: A fund that tracks
an index of a limited number of cryptocurrencies is not
diversified. In addition, cryptocurrency values tend to
be highly correlated, which would reduce the potential
benefits of diversification even if the number of
cryptocurrencies tracked by an index were to increase.
Such an investment should be considered speculative
and only be considered by investors willing to bear the
risk of total loss;
• From 0.35% to 0.30% for accounts valued at
$3,000,000.01 - $5,000,000;
• From 0.25% to 0.20% for accounts valued at
$5,000,000.01 to $10,000,000; and
• From 0.20% to 0.10% for accounts valued at
• Valuation: Unlike a stock that represents an
ownership interest in a company or a fixed income
security that represents a debt owed by the issuer,
cryptocurrencies typically have no intrinsic value tied
to cash flow, dividends or tangible property;
$10,000,000.01 and up.
• Regulation: While securities designed to track
cryptocurrency prices are subject to U.S. regulation,
cryptocurrency itself is largely unregulated; and
to
and
digital
For accounts valued in these ranges, the reduction of the
Program fee will be automatic. If your account is currently
charged a Program fee less than the new rates shown
above, your account will continue to be charged the lower
rate.
that
include
exposure
the unregulated nature of
• Security: Due
cryptocurrency
platforms,
asset
cryptocurrency may be more susceptible to fraud,
manipulation, security failures or operational failures
than traditional asset classes.
Additional information regarding the risks associated with
investments in cryptocurrency can be found in the fund’s
prospectus.
Item 6 – Portfolio Manager Selection and Evaluation.
Investment models
to
cryptocurrency have been added to the Program. If you
are interested in learning more about these models,
please contact your financial advisor. Item 6 has been
expanded to include the following cryptocurrency risk
disclosure.
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Table of Contents
Item 1 – Cover Page… ....................................................................................................................1
Item 2 – Material Changes ............................................................................................................2
Item 3 – Table of Contents… .........................................................................................................3
Item 4 – Services, Fees, and Compensation ...............................................................................4
Item 5 – Account Requirements and Types of Clients .............................................................14
Item 6 – Portfolio Manager Selection and Evaluation, Risk of Loss .......................................15
Item 7 – Client Information Provided to Portfolio Managers .................................................17
Item 8 – Client Contact with Portfolio Managers .....................................................................17
Item 9 – Additional Information .................................................................................................18
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Item 4 – Services, Fees
and Compensation
(“SMA”) strategies also are available. Within this brochure and
in other program-related documents, both model-delivery
strategies and discretionary SMA strategies are generically
referred to as investment models or “Models.”
About Primerica Advisors
Primerica Advisors is the trade name under which PFS
Investments Inc. (“PFSI”) conducts its investment advisory
business. PFSI, a SEC-registered investment adviser and
broker-dealer, is an indirect, wholly owned subsidiary of
Primerica, Inc., a financial services company that is publicly
traded on the NYSE. In addition to offering the wrap fee
program described in this brochure, Primerica, Inc., through
its subsidiaries, assists its clients in North America by meeting
their needs for term life insurance, underwritten by Primerica
Life Insurance Company, mutual funds, annuities and other
financial products, which are distributed primarily on behalf
of third parties.
The Lifetime Investment Program Overview
For model-delivery strategies, Primerica will buy and sell
securities in your account consistent with the holdings of the
strategy. Primerica intends to implement the model-delivery
strategies as provided by the Asset Managers and generally
does not make changes to the securities or asset allocations
provided by an Asset Manager. Primerica uses third-party
service providers in support of its obligations under the
Program and has entered into agreements with Pershing
and its affiliates to provide technology, administrative and
portfolio management services. In connection with these
services, Primerica delegates investment discretion and
trading authority to BNY Mellon Advisors, Inc., an affiliate of
Pershing, to serve as overlay manager for the program. As
overlay manager, BNY Advisors, Inc. will place orders to buy
and sell securities in your Program Account consistent with
the model-delivery strategies you have selected.
(“Program”). The Program
This brochure describes the Primerica Advisors Lifetime
Investment Program
is a
discretionary asset management program through which
Primerica Advisors (“Primerica”) and its investment adviser
representatives (“Advisors”) provide advisory services.
For accounts invested in a discretionary SMA strategy, clients
will grant discretionary trading authority to the discretionary
SMA Asset Manager who will place orders to buy and sell
securities in your account consistent with the holdings of the
strategy.
The Program provides you with access to investment
strategies designed to support various investment objectives,
while taking into consideration your preferences related
to market exposure, taxes, and securities selection. The
strategies are created and managed by unaffiliated asset
management firms (“Asset Managers”). You pay an annual
wrap fee (described below) for the services provided through
the Program.
Primerica Advisors as Sponsor and Portfolio Manager
Models that invest in mutual funds generally will purchase
an institutional or similar share class that does not charge
an upfront sales charge or an annual 12b-1 fee. In the event
that an Asset Manager includes a non-institutional share class
in a Model, Primerica generally will request that the Asset
Manager replace the fund. If 12b-1 fees are paid in connection
with mutual fund transactions, such fees will be credited to
your Program Account. If a Model contains a mutual fund
or other holding that Primerica is unable to purchase or is
otherwise administratively unable to process, then Primerica
will request that the Asset Manager provide an alternative.
Primerica is the sponsor and discretionary portfolio manager
for the Program. In this capacity, Primerica evaluates Asset
Managers and their investment strategies for inclusion in the
Program. As part of its evaluation process, Primerica relies on
an unaffiliated due diligence consultant to review each Asset
Manager and strategy that is considered for the Program.
The due diligence consultant also provides services to the
Program in connection with Primerica’s ongoing oversight of
the Asset Managers.
The Asset Managers provide ongoing investment advice to
the Program through their respective strategies. The Program
primarily consists of model-delivery strategies, however, a
limited number of discretionary separately managed accounts
Primerica conducts ongoing due diligence of the Asset
Managers, and, in its discretion and without prior notice, may
add a Model, close a Model to new investments or remove
a Model from the Program. If Primerica removes a Model
from the Program, or an Asset Manager withdraws from
the Program, Primerica, as necessary, will sell all Program
holdings associated with the Model, without regard to cost
basis or tax consequences. If you are invested in a Model
that is removed or withdrawn from the Program, Primerica
will, at its discretion, either reinvest your assets in one or
more replacement Models that are consistent with your
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Investment Profile; or hold your assets in cash until you select
a replacement and communicate your selection to Primerica.
Conservative Growth, Conservative, and Fixed Income.
The Models are described generally as Strategic or Tactical
based on the investment style of the Asset Manager.
Income distribution and tax managed Models also are
available.
Strategic Models generally employ a longer-term outlook
and will remain fully invested according to the Model’s
targeted asset allocation. The Asset Managers of Strategic
Models periodically will adjust the weightings of the asset
classes within a Model based on the Asset Manager’s
economic outlook. However, Strategic Models generally will
not engage in market-timing transactions or replace equity
or fixed-income holdings with cash. Typically, Strategic
Models will engage in less trading than Tactical Models.
Investments in the Program are held and managed in an
account (“Program Account”) registered in your name.
Primerica, directly or through its service providers, periodically
will place trades in your Program Account so that the holdings
remain consistent with those of the Models you have selected,
allowing for reasonable variation due to fluctuations in asset
values and the time required to implement Model changes.
Unless stated otherwise in this brochure, trades will occur
without regard to tax consequences or cost basis and may be
initiated as a result of deposits into or withdrawals from your
Program Account, periodic rebalancing due to changes in the
relative market value of investments that caused deviations
from a Model, or changes to the Model made by the Asset
Manager. If your Program Account holds two or more Models,
at its discretion, Primerica will place trades in your Program
Account so that the assets are apportioned according to the
percentages you select for each Model.
Asset Managers offering Tactical Models generally focus on
shorter-term economic conditions and will tend to adjust
the holdings and the asset allocation of a Model more
frequently. Tactical Models, like Strategic Models, will have
a targeted asset allocation. However, Tactical Models at
times deviate from the targeted asset allocation and invest
significant portions of the Model’s holdings in cash or cash
alternatives. Tactical Asset Managers also may respond to
perceived market conditions by significantly reducing or
eliminating exposure to one or more of the non-cash asset
classes within a Model.
Program Accounts will be managed according to the Model(s)
identified in your Lifetime Investment Program Proposal.
Subject to Primerica’s discretionary authority to remove a
Model from the Program and to administer underfunded
Program Accounts, unless you notify Primerica, in a form
acceptable to us, your Program Account will remain invested
in the Models identified in your Lifetime Investment Program
Proposal.
Both Strategic and Tactical Models offer potential risks and
rewards.
in the Program do not enter
Investors
into written
contractual agreements with any of the Asset Managers. If
a service provider or Asset Manager is required to deliver to
you a copy of its Form CRS and/or Form ADV, you authorize
Primerica, as permitted by law, to accept such delivery on
your behalf. Copies of these disclosure documents are
available upon request.
Strategic Models, because they remain fully invested,
generally are expected to experience greater swings in value
during periods of equity market volatility. However, because
they remain fully invested, the long-term performance of
Strategic Models generally will be less dependent on the
timing of the investment decisions made in connection with
the management of the Model.
Asset Managers and Models
Each of the Asset Managers is a registered investment
adviser that creates and manages investment strategies
that are made available to investors directly and/or
indirectly through advisory programs, such as the Lifetime
Investment Program. The Asset Managers create and
manage their respective Models utilizing various investment
philosophies and types of securities.
The Tactical Models in which the Asset Managers have the
option to overweight cash holdings may experience less
volatility than other Models. However, Tactical Models may
underperform relative to Strategic Models based on the
timing of the Asset Manager’s decision to move into and out
of cash or other asset classes, particularly in situations when
an Asset Manager’s decision to move out of cash occurs
after equity markets have started to trend upward, or if such
moves conflict with the general direction of the markets.
The Models are designed with asset allocations ranging
from 100% equity to 100% fixed income. Each Model is
categorized according to one or more of six investment risk
profiles: Aggressive Growth, Growth, Moderate Growth,
Income Distribution Models are designed and managed
specifically to distribute income in set amounts or over set
periods of time. For information regarding a specific Income
Distribution Model, please ask your Advisor.
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Tax Managed strategies fall into one of three general
categories. For information regarding a specific Tax Managed
strategy, please ask your Advisor.
is presented both gross of advisory fees, that is with no fees
deducted, and net of advisory fees. Gross performance
typically represents the actual performance of the Model
under the discretionary management of the Asset Manager,
sometimes referred to as the Asset Manager’s composite
in fact cards
performance. Net performance shown
generally is calculated by reducing the Asset Manager’s gross
performance by an amount equal to the maximum annual
fee charged by Primerica to Program assets invested in the
Model.
1. Active Tax Loss Harvesting: Customized, manager-
traded strategies in which an asset manager will actively
monitor gains and losses associated with the individual
stocks held in your account and will harvest losses (sell)
to offset gains and limit capital gains taxes. The manager
will have investment discretion over your assets and the
authority to place orders to buy and sell securities in your
account.
2. Tax Exempt: Customized, manager-traded strategies
and model-delivery strategies focused on generating tax
exempt income through direct ownership of municipal
bonds, or through ownership of exchanged traded funds
and mutual funds that hold municipal bonds. Depending
on the strategy you select, either the manager will have
investment discretion over your assets and the authority
to place orders to buy and sell securities in your account,
or alternatively, Primerica Advisors will implement the
selected model as described above.
If you receive an investment proposal that includes the
blended performance of two or more Models, the blended
performance calculation
is considered hypothetical
performance. This is because the blended performance
represents a proposed combination of Models within
a proposed portfolio and not an actual account of any
client. The use of actual performance of individual Models
to create a blended performance illustration is intended
to help you understand how a portfolio would have
performed historically using the proposed combination of
Models. However, you should keep in mind that blended
performance illustrations are created with the benefit of
hindsight. There is no guarantee that a blended portfolio
will perform in the future as it has in the past. Performance
data for your existing investment portfolio, if any, does not
consider changes to your existing holdings over the time
period illustrated.
3. Tax Aware: Model-delivery strategies invested in mutual
funds that seek to reduce capital gains tax exposure by
limiting turnover of equity securities and reduce income
taxes through municipal bond holdings. Primerica
Advisors will implement the selected model as described
above.
There is no guarantee that any strategy, regardless of the
asset allocation or investment style, will result in positive
investment performance or achieve an investor’s objectives.
For model-delivery strategies, the investment performance of
assets invested in the Program will differ from the investment
performance of assets invested in the same Model or similar
strategy under the discretionary management of the Asset
Manager who provides the Model.
ESG Strategies
With respect to models that hold stock, Primerica has
established a policy to exclude the stock of its parent company,
Primerica, Inc. (PRI) from Program Accounts. This restriction is
implemented by the Overlay Manager, as needed.
Detailed information about each of the Asset Managers is
available from Primerica and your Advisor. Before investing
in any of the Models you should carefully review an Asset
Manager’s materials, including its Form CRS and Form ADV
Part 2A.
Investment Performance
IInformation about the investments offered through the
Program is available from your Advisor. Typically, there is a
“fact card” for each Model that contains information about
the Asset Manager, a Model’s objective, and if available,
historical investment performance. Historical performance
ESG (Environmental Social Governance) is a method of
analysis in which an asset manager considers factors,
such as environmental practices, diversity and inclusion in
hiring and corporate governance policies, among others,
when determining whether to buy or sell a particular
security. Certain ESG strategies also incorporate faith-
based considerations. ESG factors typically are evaluated
in conjunction with traditional metrics, such as a company’s
revenue, sales, and expected growth, as well as broader
market conditions and economic trends. In general, ESG
investing is intended to influence corporate behavior across
a range of issues and provide investors with the opportunity
to express their values through their investment choices.
ESG investing does not guarantee any specific corporate
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outcome and should not be viewed as a promise of superior
investment performance.
created for a specific purpose. Primerica reserves the right to
amend its administrative forms, procedures, and policies at
any time without prior notice.
Brokerage and Custodial Services
Because there is no single standard for ESG analysis, you
should carefully review an Asset Manager’s ESG assumptions
and process to understand how ESG screening is applied to
a particular Model. For information about the ESG strategies
available in the Program, please consult with your Advisor.
Your Advisor
Primerica arranges with Primerica Brokerage Services, Inc.
(PBSI) to be the introducing broker-dealer to the Program.
PBSI has contracted with Pershing LLC (Pershing) to act as its
clearing agent. Pershing will provide custody, trade execution,
clearing, settlement and other services for all Program
Accounts. Pershing is a qualified custodian, as defined in Rule
206(4)-2 of the Investment Advisors Act of 1940. Investors
in the Program direct Primerica to place all transactions in
Program Accounts through PBSI and Pershing. PBSI may not
always obtain as favorable a price as another broker-dealer. By
directing Primerica to place all Program Account transactions
through PBSI and Pershing, investors in the Program agree to
look only to PBSI and Pershing to obtain best execution. Please
refer to the PBSI Client Agreement for additional information.
To determine which Models are appropriately suited to
your needs, your Advisor will assist you with completing an
Investment Profile. This process is used to identify Models that
are consistent with your investment objective, risk tolerance,
and investment time horizon. Your Advisor may also collect
additional information regarding your preferences related
to market exposure, tax concerns, securities selection and
investment lifecycle. Using this information, your Advisor will
present for your consideration a Model or Models for your
Program Account.
Directing brokerage to PBSI and Pershing may result in
you receiving less favorable execution terms than might be
obtained from another broker-dealer and could increase
your cost of investing. Other advisory programs may allow
you broader discretion to select a broker-dealer. Alternatively,
other advisors may agree to accept responsibility for selecting
broker-dealers on your behalf. You will receive account
statements, transaction confirmations, tax forms, and other
correspondence, as applicable, from PBSI and Pershing. You
should carefully review all account statements and other
communications you receive related to your accounts.
Primerica Advisors and PBSI are affiliates and both are indirect
subsidiaries of Primerica, Inc.
After your Program Account is opened, your Advisor will be
available on an ongoing basis to discuss your participation in
the Program. It is your responsibility to notify your Advisor of
any significant changes in your financial circumstances. You
and your Advisor will then determine whether to reconsider
the Models selected for your Program Account. It is your
responsibility to tell your Advisor if you wish to change the
Models held in your Program Account. At least once a year,
your Advisor or Primerica will undertake reasonable efforts to
contact you to determine if there have been any significant
changes in your financial situation or investment objectives,
and whether you wish to change your existing instructions or
impose any new restrictions regarding the management of
your Program Account. Your Advisor does not have discretion
to change the Models held in your Program Account.
Opening a Program Account
Unless you select another option available from PBSI, any cash
balances in a Program Account will be held in the default cash
sweep option indicated in the PBSI new account application.
Cash held in a money market fund is neither insured nor
guaranteed by the Federal Deposit Insurance Corporation or
any other government agency.
PBSI reserves the right not to accept a deposit of funds or
particular securities. Please see the PBSI account agreement
and related agreements and disclosures for additional
information. Funds or securities not accepted by PBSI are
ineligible to be used as a funding source for a Program
Account. PBSI does not accept certificated securities or any
other physical securities.
In general, to receive the services offered by the Program, you
must 1.) Receive and approve a Lifetime Investment Program
proposal; 2.) Accept the Lifetime Investment Program Advisory
Agreement (“Advisory Agreement”); and
3.) Complete and accept a Primerica Brokerage Services, Inc.
(PBSI) new account application and agreement. A Program
Account is not eligible to be funded until after the application
and agreements are reviewed and approved by Primerica
Advisors and PBSI. Primerica requires that certain types of
communications be submitted in writing and/or on forms
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is processed and the block orders in which your assets
are included are placed by Primerica and executed. Once
executed, block orders are allocated to individual Program
Accounts after the market close and may not be viewable in
your Program Account until the next day.
Pershing serves as the IRS-approved IRA custodian for
Program assets held in accounts described in IRC section
403(b)(7), and individual retirement accounts established
under IRC section 408 (collectively referred to as “Retirement
Accounts”). If your Program Account is a Retirement Account,
then you will be subject to the terms of the applicable Pershing
IRA Application and Custodial Agreement. Primerica’s ability
to manage your Program Account is subject to the terms and
conditions contained in the PBSI Client Agreement and PBSI’s
agreements with Pershing. Restrictions imposed by PBSI and
Pershing may prevent or delay Primerica’s ability to open and/
or manage your Program Account.
For discretionary SMA strategies, the Asset Manager has
discretion to select the broker-dealers through which it
will execute securities transactions. Pershing will provide
settlement, custody, reporting and other services for manager-
traded transactions executed through the broker-dealers
selected by the Asset Manager. For information regarding the
Asset Manager’s trading practices, including best execution,
please refer to the Asset Manager’s Form ADV brochure.
For taxable accounts, transactions are managed to avoid
violations of the IRS wash sale rule. Typically, if a security is
sold at a loss, a taxpayer receives a potential tax benefit by
reducing any taxable capital gains up to the amount of the
loss. Additionally, up to $3,000 in losses can be deducted
from ordinary taxable income, and any excess losses can
be carried over for use in future tax years. However, if a
security is sold at a loss and a wash sale has occurred, the IRS
will not recognize the loss and will not allow a deduction. A
wash sale occurs when an investor purchases the same or
a substantially identical security 30 days before or after the
sale that generated the loss. This practice is intended to help
investors accumulate deductible capital losses and potentially
reduce taxes. If a transaction is held to avoid a wash sale, it
will cause your account to temporarily deviate from the model
until the transaction is executed.
Trading Practices and Order Processing
For model-delivery strategies, please see the overlay
manager’s Form ADV brochure for additional information
regarding trading practices. For discretionary SMA strategies
please refer to the Asset Manager’s Form ADV brochure
for information regarding trading practices, including best
execution and order aggregation.
Non-Program Accounts
As an accommodation to participants in the Program, a Non-
Program Account (“NPA”) is available to clients who wish to
hold assets outside of the Program Models. The Non-Program
Account is a self-directed account. Neither Primerica nor your
Advisor will provide investment advice for the assets in a Non-
Program Account or place orders in a Non-Program Account
on your behalf. For all transactions in a Non-Program Account,
you must contact PBSI directly.
The Lifetime Investment Program is an asset management
program in which large numbers of clients are invested
according to the same or similar investment strategies, and
therefore own shares of the same securities. To administer
the Program efficiently and seek improved trade execution,
securities trades associated with the management of your
individual Program Account are typically aggregated with the
trades of other clients invested in the Program. This means
that when securities are bought and sold for your Program
Account, including trades related to Model updates submitted
by an Asset Manager, rebalancing transactions, and client-
initiated transactions, such as withdrawals, transfers between
Models and liquidation requests, trades for your Program
Account are combined with those of other clients and placed
as block orders. Trades placed through block orders may
be executed at multiple prices, in which case the trades will
be allocated to individual Program Accounts based on the
average price per unit of the executed trades.
Client-initiated transactions in existing Program Accounts
will be included in the block trades on the day the request
transactions received by
is processed. Client-initiated
Primerica in good order typically are processed within three
to five business days. During periods of high trading volume,
processing times may be longer. Your Program Account will
remain allocated to your Model selections and subject to all
risks associated with the Models until your request
To establish a Non-Program Account, you must identify the
specific securities you wish to hold as Non-Program Assets.
By entering into the PBSI account agreement, you authorize
Primerica to establish a Non-Program Account on your
behalf and authorize Primerica to instruct the custodian to
hold any securities identified as Non-Program Assets in the
Non-Program Account. If at any time you transfer securities
held in a Non-Program Account to your Program Account,
Primerica will consider such action as an instruction from you
to liquidate the securities and to invest the proceeds in the
Models held in your Program Account.
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Program: The Program fee is determined according to the
following schedule.
Account Value
Program
fee
$250,000 or less
0.49%
$250,000.01 - $500,000
0.46%
$500,000.01 - $1,000,000
0.42%
$1,000,000.01 - $3,000,000
0.38%
0.30%
$3,000,000.01 -
$$5,000,000
Non-Program accounts are offered as an accommodation
to clients with an active advisory agreement with Primerica.
By entering into the Advisory Agreement, you grant “view
only” access for your Non-Program Account to Primerica and
your Advisor. Primerica reserves the right to monitor trading
activity in Non-Program Accounts consistent with applicable
law. Assets in a Non-Program Account are not considered by
Primerica or your Advisor in connection with the management
of your Program Account. The fees applicable to Non-
Program accounts are established by PBSI and are separate
from the annual wrap fee (discussed below) that you will pay
to Primerica Advisors.
0.20%
Fees
$5,000,000.01 -
$10,000,000
$10,000,000.01 +
0.10%
Investors in the Program agree to pay an annual wrap fee
(“Wrap Fee” or “Fee”) for the services provided through the
Program.
The Program fee is the component of the Wrap Fee charged
by Primerica Advisors for its services as sponsor, portfolio
manager and the administrator of the Program, as well as for
the custody and brokerage services provided to the Program.
The Program fee generally is not negotiable.
The Wrap Fee you pay is described in the Lifetime Investment
Program Proposal as the Total Fee. The Wrap Fee consists of
three components: 1. Advisory Fee; 2. Program Fee; and
3. Asset Manager Fee. These components are combined to
determine your total cost to invest in the Program.
Advisory: The Advisory fee is determined according to the
following schedule.
Account Value
Advisory fee
(Maximum)
$250,000 or less
1.25%
$250,000.01 - $500,000
1.25%
$500,000.01 - $1,000,000
1.10%
$1,000,000.01 - $3,000,000
1.00%
$3,000,000.01 - $5,000,000
0.85%
0.80%
$5,000,000.01 -
$10,000,000
$10,000,000.01 +
0.75%
Asset Manager: The Asset Manager fees range from 0.00%
to 0.50% annually depending on the Models selected for the
Program Account. The Asset Manager fee is what you pay for
the services provided to the Program by the Asset Manager.
Asset Manager fees vary so that your Wrap Fee will be more
or less depending on which Model(s) you select for your
Program Account. Certain Asset Managers, or their affiliates,
serve as the investment adviser to the mutual funds or ETFs
that are used to construct the Asset Manager’s Models. These
Asset Managers, or their affiliates, receive compensation
from the fees and expenses charged to the shareholders of
the mutual fund or ETF. The Wrap Fee for Program Accounts
invested in the Models provided by such Asset Managers may
not include an Asset Manager fee component. Please speak
with your Advisor regarding Models that include or are limited
to proprietary mutual funds or ETFs, including whether there
is an Asset Manager fee for the Model. Additional information
regarding Models that include proprietary mutual funds
or ETFs is located in this brochure under the heading Other
Considerations Regarding Fees.
The Advisory fee is the component of the Wrap Fee you pay
for the advice and services provided to you by your Advisor.
A portion of the Advisory fee is retained by Primerica
Advisors. The Advisory fee is negotiable.
The Lifetime Investment Program Proposal that you sign
will include a fee schedule that establishes the rates
your Program Account will be charged for each of the
fee components. These rates will be used to determine
your annual Wrap Fee and to calculate the amount of the
Wrap Fee due each billing cycle.
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The actual fees you pay will vary depending on the value of
your Program Account when the fees are calculated for each
monthly billing cycle. The Asset Manager fee and Program fee
generally are not negotiable.
Account A and Account B are in a Billing Group, and
Account A has a value of $850,000 and account B has a
value of $200,000, then each would be considered to have
reached the $1,000,000 tier for purposes of calculating
the amount due for the Advisory Fee and Program Fee for
each Program Account.
As an accommodation to clients seeking temporarily to reduce
exposure to market volatility, you are permitted to allocate
your Program Account entirely to cash. Program Accounts
allocated to cash are subject to a reduced annual wrap fee
of 10 basis points. Because of this reduced fee, Primerica
and your Advisor have an incentive to recommend that you
reinvest your assets into a Model subject to the standard
annual wrap fee. Primerica reserves the right to limit the
availability of this option.
Opportunities to Reduce the Annual Wrap Fee
The Program provides you with the following opportunities to
reduce the cost of investing.
Whether a Program Account is included in a Billing Group
is negotiated between you and your Advisor. Inclusion in a
Billing Group is not a guarantee that your fees will be lower.
The fee schedule tier applicable to the Program Accounts in a
Billing Group, and therefore the fees paid by those Program
Accounts, may change based on fluctuations in the value
of the Program Accounts in the Billing Group, and based
on Program Accounts being added to or removed from the
Billing Group. If you own Program Accounts that you have not
negotiated to include in a Billing Group, you may pay more
in fees than you would have if the Program Accounts were
included in a Billing Group. If you have a Program Account that
is not part of a Billing Group and another that is in a Billing
Group, then you may pay more in fees in both accounts as
neither Program Account would receive the potential benefit
associated with combining the holdings into the same Billing
Group. Billing Groups are permitted to include Program
Accounts of different owners; however, the determination of
the fee tier applicable to a Billing Group will not consider any
Program Accounts not included in the Billing Group regardless
of ownership. Primerica reserves the right to disallow the
inclusion of an account in a particular Billing Group.
How the Wrap Fee Is Assessed
1. Negotiated Advisory Fee – The Advisory fee component
of the annual wrap fee is negotiable between you and
your Advisor within limits set by Primerica Advisors. For
each Program Account you establish, the Advisory Fee
agreed to between you and your Advisor will be contained
in the Lifetime Investment Program Proposal associated
with a specific Program Account. Therefore, the Advisory
Fee component of the annual wrap fee may be different
for each Program Account you own. As a result, you may
have a higher Advisory Fee in one Program Account than
you do in another. Because the Advisory fee is negotiable,
it is possible that you will pay more or less than other
clients receiving the same or substantially similar services.
2. Tiered Fee Schedules – The fee schedule for the
Lifetime Investment Program is tiered so that at certain
investment levels the Advisory Fee and Program Fee
are reduced as the value of an account increases. If
your Program Account value moves into a higher tier,
through market appreciation or deposits, your fees will
automatically adjust based on the rates contained in a
Program Account’s fee schedule. For each billing cycle,
only the rates contained in the applicable tier of the fee
schedule are used to calculate the amount due for each
of the components of the annual wrap fee. Your fees may
increase if the value of your Program Account declines
causing it to move into a lower tier.
The annual Wrap Fee is payable in arrears on a monthly
basis. For purposes of determining the amount of the Wrap
Fee that you will be charged each billing cycle, Primerica will
calculate the total market value of your Program Account at
the end of each business day, defined as any day the New
York Stock Exchange is open for trading, including trading
on an emergency venue. Based on an average value of your
Program Account during the relevant billing cycle, Primerica
will charge you a prorated share of the annual Wrap Fee
according to the Fee Schedule applicable to your Program
Account, taking into account whether the Program Account
is included in a Billing Group. For the initial month that you
are invested in the Program, you will pay a prorated Wrap Fee
based on the average daily value of the assets from the date
your Program Account is funded through the last day of the
monthly billing cycle.
3. Billing Groups – A Billing Group consists of two or more
Program Accounts that are grouped for purposes of
calculating the Advisory Fee and Program Fee for each
Program Account in the Billing Group. For example, if
For Program Accounts invested in Models that assess different
Asset Manager fees, the Wrap Fee is adjusted based on the
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related administrative services are not covered by the annual
wrap fee. ADR-related fees may be reflected in the net price
received for the ADR or appear as a line-item fee on your
account statement.
portion of the Program Account allocated to each Model. The
Wrap Fee deducted from your Program Account, when stated
as a percentage, may vary from the percentage shown in your
Fee Schedule based on the amount of your Program Account
that is allocated to each Asset Manager at the time the Wrap
Fee is calculated.
Taxes and Regulatory Fees: SEC regulatory fees and taxes
associated with activity in your account are not covered by the
Wrap Fee. Such fees and taxes may appear on a transaction
confirmation or your account statement.
All assets held in the Program Account are subject to the Wrap
Fee, including assets acquired through dividend reinvestments
and automatic investment programs, as well as any portion
of the Program Account maintained in cash or short-term
vehicles including, but not limited to, money market funds.
For administrative purposes, the monthly billing cycle may not
track an exact calendar month.
The Wrap Fee does not include the charges, if any, for ancillary
services provided by PBSI or Pershing, such as returned
checks or drafts, express mail fees, wire transfer fees and fees
associated with a Non-Program Account. Please see the PBSI
fee schedule for additional information regarding fees for
ancillary services.
Other Considerations Regarding Fees
Certain of the Asset Managers whose Models are included in
the Program offer the same or similar investment strategies
directly to investors. Before investing in the Program, you
should consider whether you are eligible to have your assets
managed directly by the Asset Manager, and whether it would
be less expensive to do so.
Primerica will debit the Wrap Fee directly from your Program
Account. Primerica, in its discretion, will determine which
assets in the Program Account will be liquidated to cover the
Wrap Fee, without regard to tax consequences or cost basis.
Pershing will send you a statement, at least quarterly, indicating
all amounts disbursed from your Program Account, including
the amount of the Wrap Fee. If the Advisory Agreement is
terminated other than on the last day of a monthly billing
cycle, a prorated Wrap Fee will be assessed for the month
in which the termination occurred. The Wrap Fee will be
deducted from the liquidation proceeds. In certain instances,
and in our discretion, Primerica may reduce your Wrap Fee
for one or more monthly billing cycles. Upon notification to
Primerica that the owner of a Program Account is deceased,
management of a Program Account will be discontinued if
there is no surviving joint owner. A prorated Wrap Fee will be
assessed for the month in which the notification was received.
Additional Fees You May Incur
Mutual Funds and ETFs: The mutual funds, ETFs and other
exchange traded products (ETPs) held in your account charge
fees and expenses that are in addition to the Wrap Fee. The
fees and expenses of the mutual funds and ETFs, including
management fees, distribution fees and administrative
expenses, are discussed in each fund’s prospectus or statement
of additional information and are charged against the assets
in the fund. You will not pay a sales charge or a brokerage
transaction fee on the purchase or sales of securities in your
Program Account. Some mutual funds impose short-term
trading fees, as described in their prospectuses.
Additionally, certain Asset Managers construct their Models,
in whole or in part, using proprietary mutual funds and
ETFs. Meaning the mutual funds and ETFs are sponsored by
an affiliate of the Asset Manager, and the Asset Manager,
or an affiliate, is an investment adviser to the mutual funds
and ETFs. Models that exclusively utilize proprietary mutual
funds generally do not assess an Asset Manager fee. If a
Model is available without an Asset Manager fee, then the
Asset Manager will receive no compensation from the Wrap
Fee. Instead, the Asset Manager, or its affiliate, will receive
compensation from the fees charged by its proprietary
mutual funds or ETFs held in the Model. If a Model includes
proprietary funds and charges an Asset Manager fee, then the
Asset Manager, or its affiliates, will receive compensation from
both the Wrap Fee and the fees charged by its proprietary
mutual funds or ETFs held in the Model. Generally, Models
that do not charge an Asset Manager fee are limited to
proprietary mutual funds or ETFs. However, the Program may
include Models that are limited to proprietary funds and that
also charge an Asset Manager fee. For additional information
regarding Models that include proprietary mutual funds or
ETFs, including whether there is an Asset Manager fee for the
Model, please speak with your Advisor.
When selecting a Model, you should carefully consider
your investment objective, the Wrap Fee and each of its
American Depository Receipts (“ADR”): ADRs are a form of
equity security that allow investors in the United States to
invest in the stock of foreign corporations without transacting
through a foreign exchange. Costs associated with the ADR
depository bank’s holding the underlying securities and
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components, and whether the Model includes or is limited to
proprietary funds. Models for which there is no Asset Manager
fee provide you with the opportunity to reduce your Wrap
Fee. However, the full cost of a Model is the Asset Manager
fee plus the annual fees charged by the mutual funds or ETFs,
if any, held in the Model. Even though a Model charges no
Asset Manager fee, the fees charged by the mutual funds and
ETFs could cause the full cost of a Model to be more than a
Model that does charge an Asset Manager fee. Information
regarding the annual expenses charged by a mutual fund or
ETF can be found in a fund’s prospectus.
the selection of mutual fund families available through
PFSI’s broker-dealer business is significantly more limited
compared to the universe of mutual funds from which the
Asset Managers can select when creating a Model. Investors
interested in individual stocks, bonds or ETFs and having
access to a broader range of mutual funds are unable to satisfy
those preferences unless they invest through the Program. As
a result, Primerica Advisors has a potential conflict of interest
that could cause the firm and its Advisors to recommend the
Program to such an investor. Primerica mitigates this conflict
through disclosure.
Because of the fees associated with investing through
a wrap fee program, such as the Lifetime Investment
Program, assets invested in a Model through the Program
generally may experience reduced investment performance
compared to assets invested in the same or similar strategy
managed directly by the Asset Manager at a lower cost outside
of the Program.
Rebalancing and other transactions performed to facilitate
changes to the Models in your Program Account will not result
in any additional charges. The frequency of transactions within
your Program Account will vary based on the investment style
of the Models you select, and the adjustments made to the
Models by the Asset Managers. Generally, Tactical Models
are likely to experience a greater frequency of trading than
Strategic Models. As a result, paying a fixed fee that covers
transactions may be of more benefit to clients who select
Models with more frequent trading.
Individual stocks, bonds, ETFs and other ETPs are not
available through PFSI’s broker-dealer business. Additionally,
the selection of mutual fund families available through
PFSI’s broker-dealer business is significantly more limited
compared to the universe of mutual funds from which the
Asset Managers can select when creating a Model. Investors
interested in individual stocks, bonds or ETFs and having
access to a broader range of mutual funds are unable to satisfy
those preferences unless they invest through the Program. As
a result, Primerica Advisors has a potential conflict of interest
that could cause the firm and its Advisors to recommend the
Program to such an investor. Primerica mitigates this conflict
through disclosure.
Compensation
Primerica is compensated through the receipt of a portion of
the Wrap Fee and will continue to receive such compensation
for as long as your assets remain in the Program. Your
Advisor is compensated through the receipt of a portion of
the Advisory fee component of the Wrap Fee. The amount
of this compensation may be more or less than what would
be received if you paid separately for the investment advice,
brokerage and other services provided by the Program or
participated in other types of advisory or brokerage programs.
Participating in the Program may cost you more or less
than purchasing advice, brokerage services and custody
separately, depending on factors such as the cost of the
services if provided separately and the level of trading in the
account. You may be able to purchase the securities held in
the Program Account in a brokerage account outside of the
Program, which may be more economical depending on
a number of factors including, share class availability, the
length of time the securities are held, whether you pay an
annual advisory fee, whether you pay a front-end or back-
end sales charge, the level of trading activity in the account,
and whether mutual fund shares, if any, are purchased from
a single fund family or multiple fund families. Generally, the
type of clients that may find a commission-based account to
be a more cost-efficient option are those who plan to buy and
hold their mutual funds for long periods, those that will qualify
for breakpoint commission discounts, and those that are
not interested in the investment advice, active management
and additional services offered through the Program. You
should carefully consider whether your financial needs are
best met through an account with potentially lower costs that
offers fewer services or through an account with potentially
increased costs that provides you with enhanced services,
such as ongoing investment advice and monitoring. If you
plan to sell securities or liquidate other investment vehicles
to fund your Program Account, you should also consider the
cost of any back-end sales charges, surrender penalties, taxes,
other fees, or loss of contractual benefits that you may incur.
Individual stocks, bonds, ETFs and other ETPs are not
available through PFSI’s broker-dealer business. Additionally,
Additionally, if you invest in mutual funds through PFSI’s
brokerage business, or invest in annuities through PFSI
or its affiliates, your Advisor typically will receive upfront
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manager who is unwilling to agree to the compensation will
not be approved for, or retained in, the Program.
Primerica Advisors’ Conflicts with Respect to
Rollovers and other Asset Transfers
Primerica Advisors’ compensation is derived from the Wrap
Fee charged to assets held in a Program Account. Therefore,
we have an incentive to encourage you to transfer assets out
of your employer sponsored retirement plan, accounts at
other financial institutions and brokerage products sold by
PFS Investments into a Program Account. We mitigate this
conflict by disclosing it to you, through our obligation as a
fiduciary to act in your best interest, and through our policies
and procedures designed to ensure that an investment in the
Program is consistent with your best interest.
Promotional Items and Seminar Support Provided to
Investment Adviser Representatives
compensation based on the amount of your investment,
as well as annual trail commissions based on your account
value. The amount of compensation received annually
from the Advisory fee typically will be less than the upfront
compensation generated by an investment in mutual funds
or an annuity, but more than an annual trail commission
generated by an investment in mutual funds or an annuity.
However, assuming you maintain your Program Account
for a sufficient period of time, the annual compensation
derived from the Advisory Fee will exceed the amount of
compensation that would have been received from an
equivalent investment amount in mutual funds or annuities.
Therefore, if you plan to invest for longer periods of time, your
Advisor has a financial incentive to recommend the Program
over other services offered by PFSI and affiliates. Conversely,
if you intend to invest for shorter periods of time, your Advisor
has an incentive to recommend that you invest in mutual
funds or annuities that generate upfront compensation at
the time of your investment. Primerica mitigates this potential
conflict through its supervisory practices and by disclosing it
to you.
Your Advisor will receive the same compensation regardless
of the Models recommended for your Program Account.
Primerica’s and your Advisor’s compensation will vary from
the compensation received from other investors in the
Program based on the Advisory fee agreed to between you
and your Advisor.
Compensation from Asset Managers
Advisors are permitted to conduct seminars to educate
potential clients about the Program and to encourage them
to invest through the Program. Asset Managers are permitted
to participate in and contribute to the cost of these client
seminars and provide promotional items of nominal value.
These seminars could influence an Advisor’s decision to
recommend Asset Managers that provide such support.
Primerica Advisors mitigates this conflict by disclosing it to
you and through its policies and procedures that limit the
contributions Asset Managers are permitted to make toward
client seminars and that require pre-approval from Primerica’s
supervisory personnel for such events.
Due Diligence and Wholesaling Events
On occasion, Asset Managers hold meetings at their respective
offices, or travel to a Primerica branch office, to educate
Advisors about the Asset Manager’s investment philosophy
and investment strategies. In connection with these meetings,
the Asset Manager may provide meals and entertainment
to Advisors and may contribute in whole or in part to an
Advisor’s travel and lodging expenses incurred to attend
such a meeting. These events create a conflict of interest
for Advisors who participate in that the support provided by
an Asset Manager could influence an Advisor’s decision as
to which Asset Manager to recommend. Primerica Advisors
mitigates this conflict by disclosing it to you and through its
policies and procedures.
We receive quarterly compensation from each of the asset
managers whose investment models we offer and utilize to
manage your assets invested in the Program. Each manager
will pay us a quarterly amount equal to .0075% of the value
of the Program assets managed pursuant to the manager’s
Models. For example, for a Program Account valued at
$25,000, we would receive a quarterly payment of $1.875. This
compensation creates a conflict of interest between Primerica
and you in connection with the managers we select for and
retain in the Program. Primerica mitigates this conflict: i.)
by disclosing it to you, ii.) by receiving the same percentage
amount from each manager so that our compensation is the
same regardless of which model(s) we recommend, and iii.)
through our policies and procedures that guide our selection
of managers and the ongoing, quarterly due diligence
reviews to which all managers and models are subjected.
Notwithstanding that all managers and models are subject to
initial and ongoing due diligence reviews, this compensation
influences which Models are included in the Program, as a
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Mutual Fund Share Classes
Item 5 – Account Requirements
and Types of Clients
The Program is designed for individual U.S. citizens, lawful
permanent residents, and certain U.S. entities seeking
investment advice regarding both retirement and non-
retirement assets. Primerica Advisors does not provide
investment advice to institutional clients, such as investment
companies or pension plans. Individuals who reside outside
of the United States, regardless of citizenship, generally are
not eligible to open a Program Account or remain invested in
the Program.
Participation in the Program requires a minimum investment
of $25,000.00. Certain Models have higher minimums.
For Models that include mutual funds, Primerica will seek
to invest in institutional or similar share classes that do not
impose an upfront sales charge or annual 12b-1 fee. Typically,
these share classes are only available for purchase by retail
investors through advisory programs sponsored by a financial
intermediary, or under other limited circumstances. If either
you or Primerica terminates your Advisory Agreement, then
the mutual fund companies generally will allow you to continue
to hold the mutual fund shares purchased through the
Program, but you generally will be unable to make additional
investments in those share classes. However, certain mutual
funds have policies, outlined in a fund’s prospectus, that
authorize the redemption or exchange of shares purchased
through the Program if you transfer the shares out of your
Program Account, or if either you or Primerica terminates
your Advisory Agreement.
Primerica reserves the right to terminate the Lifetime
Investment Program Advisory Agreement at any time as
described in Section 17 of the agreement. Notwithstanding its
contractual rights, Primerica generally will seek to administer
accounts that do not meet the minimum
investment
requirement in the following manner.
If a fund, or service provider authorized by the prospectus,
elects to exchange your shares, generally you will receive
Class A or similar shares of the same fund. The shares you
receive from the exchange may have annual expenses that
are higher than the shares previously held in your Program
Account, and the fund, or service provider authorized by the
prospectus, may impose a sales charge in connection with
the exchange.
If you deposit cash or securities into a Program Account
in an amount insufficient to reach the Program minimum,
Primerica will, after reasonable efforts to contact you and
without regard to tax consequences, liquidate any securities
held in the Program Account, distribute the cash balance to
you and terminate your Advisory Agreement.
Please review the prospectus for additional information
regarding a fund’s policies related to the redemption or
exchange of shares no longer held in the Program. Shares
subject to redemption or exchange may be acquired in your
Program Account at any time as changes to a Model are
implemented.
If at any time after funding your Program Account with the
minimum investment amount, the total market value of the
assets held in a Program Account falls below the Program
minimum, as a result of withdrawals or market volatility,
you authorize Primerica, at its discretion, to liquidate any
securities held in your Program Account, without regard
to tax consequences, and distribute the cash balance of
your Program Account to you. Alternatively, subject to the
investment strategies then available through the Program,
Primerica is authorized to move the assets in your Program
Account to a Model suitable for the then current value.
Primerica’s access to mutual funds and share classes within
each fund is limited to the funds and share classes offered by
those available through Pershing or its affiliates. As a result,
an Asset Manager may select for a Model a mutual fund or
share class that is not available to the Program. If an Asset
Manager selects a fund or share class not available to the
Program, Primerica will request that the Asset Manager select
an alternative. The need to select an alternative fund or share
class from the options available may result in you owning a
fund or share class with higher annual expenses than the
fund or share class originally selected by the Asset Manager.
If the value of a Program Account exceeds the Program
minimum but is insufficient to fund each of the Models
in the Program Account, Primerica reserves the right to
consolidate your holdings into a single Model. Primerica will
not consolidate assets held in separate Program Accounts.
Primerica reserves the right to accept or maintain accounts
that do not meet the minimum investment requirements.
The Models selected for your Program Account will not be
implemented until cash or securities sufficient to meet the
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minimum investment requirements are deposited into your
Program Account.
considered for the Program. The due diligence consultant
also provides services to the Program in connection with
Primerica’s ongoing oversight of the Asset Managers.
Asset Managers selected by Primerica to participate in the
Program are subject to ongoing review and evaluation. On
a quarterly basis, the due diligence consultant prepares an
evaluation report of each Asset Manager. Primerica relies
on these reports to determine whether an Asset Manager
remains in good standing or should be removed from
the Program. Primerica’s review typically does not include
any evaluation of the individual securities selected by an
Asset Manager.
Affiliations
You may terminate the Advisory Agreement within five
business days of its initial execution without charge. Thereafter,
either you or Primerica may terminate the agreement at
any time upon written notice to the other, which becomes
effective when received or as of a later date indicated in the
notice. In the event that the Advisory Agreement is terminated
for any reason, your advisory relationship with Primerica and
your Advisor will simultaneously terminate, and all features
and privileges associated with the Program will be canceled
and cease. Upon notification to Primerica that the owner
of a Program Account is deceased, management of a
Program Account will be discontinued if there is no surviving
joint owner. The existing holdings in the account(s) of the
deceased owner will be liquidated and the proceeds held
in the cash sweep vehicle associated with the account until
claimed by the decedent’s estate, account beneficiaries or
other authorized party.
No related person or affiliate of Primerica acts as a portfolio
manager for the Program. Primerica is not an affiliate of any
of the Asset Managers who provide investment Models the
Program. The Asset Managers may be public companies,
subsidiaries of public companies or privately held entities.
Neither Primerica Advisors nor its parent Company has
an ownership interest in the Asset Managers or the Asset
Managers’ respective affiliates.
Item 6 – Portfolio Manager
Selection and Evaluation
Selection and Evaluation
Investment philosophy and process
Primerica, as sponsor and portfolio manager for the Program,
selects the Asset Managers and strategies available in the
Program. The Program seeks to include strategies that align
with a range of investment objectives and risk tolerances.
Primerica’s evaluation process considers both the Asset
Manager as an entity, as well as the individual strategies
offered by the Asset Managers. Primerica uses internal and
external resources to identify and evaluate Asset Managers.
The evaluation process considers both quantitative and
qualitative factors such as.
•
• Asset manager personnel
• Assets under management
• Past performance [track record and experience]
• Modern Portfolio Theory statistics, such as Alpha, Beta,
R-squared and Sharpe ratio
• Performance relative to an appropriate benchmark
• Consistency of performance
• Performance relative to peers
• Risk adjusted return
• Total return
Primerica has hired an unaffiliated due diligence consultant
to assist with its review of the Asset Managers and strategies
Primerica has current or prior business relationships with
certain Asset Managers outside of the Program. BNY Mellon
Advisors, Inc. (formerly Lockwood Advisors) previously co-
sponsored, along with Primerica, the Freedom Portfolios
mutual fund wrap fee program, which was offered from June
2011 until February 2019. Additionally mutual funds from
Invesco, Franklin Templeton, Fidelity and American Funds are
available from PFSI through its broker-dealer business. PFSI
and its representatives receive compensation from Invesco,
Franklin Templeton, Fidelity and American Funds for the sale
of their mutual funds. Primerica Shareholder Services, an
affiliate of PFSI, receives compensation from Invesco, Franklin
Tempelton and Fidelity for administrative services provided to
owners of Invesco and Franklin Templeton funds who purchase
mutual fund shares through PFSI’s broker-dealer business.
Advisors also may have received non-cash compensation
from Invesco, Franklin Templeton and American Funds in
connection with our retail brokerage business. Due to these
factors and their prior experience and familiarity with BNY
Mellon Advisors, Invesco, Franklin Templeton and American
Funds, Advisors may be more inclined to recommend
strategies designed by those Asset Managers or their affiliates.
In addition, certain Asset Managers may make greater efforts
than others to communicate with and educate Advisors
regarding their respective strategies. As a result, an Advisor
may be more inclined to recommend the Asset Managers
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with whom the Advisor has a closer relationship. Primerica
mitigates this potential conflict through disclosure.
will remain fully invested regardless of market conditions. As
a result, Strategic Models in general may experience greater
losses during periods of market volatility compared to certain
Tactical Models, as the Asset Managers of Tactical Models
have the option to recommend substantial holdings in cash
or cash alternatives.
Primerica Advisors’ advice is limited to the assets held in a
Program Account. Primerica does not sponsor or provide
portfolio management services to any advisory programs
other than the Lifetime Investment Program. Primerica does
not accept performance-based fees.
Proxy Voting; Corporate and Legal Action
Tactical Models also entail risk, and the
investment
performance of a Tactical Model will be affected by the Asset
Manager’s decision as to if and when to move into and out
of cash or other asset classes. Significant market declines can
occur before an Asset Manager makes a decision to move
assets to cash and before Primerica Advisors has the ability
to implement Model changes. Asset Managers who employ
a Tactical investment style may remain allocated to cash or
cash alternatives during periods of market recovery following
an actual market decline, causing the Model and the Program
Accounts holding that Model to miss out on participation
in a market recovery. Similarly, Asset Managers offering
Tactical Models may incorrectly anticipate market trends and
recommend exchanging equity and fixed-income holdings for
cash or cash alternatives during periods in which equity and
fixed-income securities appreciate in value.
Income Distribution Models are designed to generate income
by distributing assets from the Program Account to you,
however there is no guarantee that such Models will generate
any specific amount of income, or that the income will be
available for a period of time sufficient to meet your needs.
Investors in the Program authorize Primerica Advisors to vote
proxies and other corporate actions. Primerica delegates
proxy voting determinations to one or more service providers,
including but not limited to an overlay manager. Primerica
or its service providers vote proxies only for assets held in
a Program Account at PBSI. Primerica will not vote proxies
or other corporate actions for securities in a Non-Program
Account or for securities held away from Pershing. You are
not permitted to direct Primerica or its service providers
how to vote any particular proxy solicitation. You may obtain
information about past votes, as well as a copy of Primerica’s
or a service provider’s proxy voting policies and procedures
upon request. You may retain your right to vote proxies by
notifying PBSI after account opening. Primerica seeks to
eliminate or mitigate conflicts of interest in proxy voting by
relying on the advice and/or services of third parties whose
proxy recommendations and voting decisions are made
independent of any interest Primerica may have in the vote.
For discretionary SMA strategies, the Asset Manager will vote
proxies on your behalf. For additional information, please
review the Asset Manager’s Form ADV brochure.
Risk of Loss
Tax Aware and Tax Exempt Models are not designed or
managed to address the specific tax needs of any individual
in
investor. Discretionary SMA strategies that engage
tax loss harvesting or invest in municipal bonds can be
customized to meet an individual investor’s needs; however,
tax considerations generally are limited to assets held in the
strategy and do not consider an investors overall tax situation.
You should consult with a tax professional for advice regarding
how investing in these strategies might affect your personal
tax situation.
Cryptocurrency Risk Disclosure
Investing in the Program entails risk, including loss of principal.
The securities held in your Program Account are subject to
multiple risks, including market, credit, liquidity, currency,
economic and political risk. Investments in the Program are
not insured by the FDIC, FCUA or any other regulatory agency,
and are not deposits or obligations of, nor guaranteed by,
Primerica, the Asset Managers, any Program services provider,
securities issuer or any of their respective affiliates. There is
no guarantee that the strategies recommended to you will
accomplish your investment objectives.
Certain Models include allocations to exchange traded
funds that invest exclusively in cryptocurrency. If you
invest in one of these models, you will not directly own any
cryptocurrency. Rather, you will own shares of a fund that
invests in cryptocurrencies, such as Bitcoin, Ether and others.
Investments in cryptocurrency involve risks, including:
• Volatility: Cryptocurrency prices can be extremely volatile
and subject to wide price swings. As such, funds that track
Strategic, Tactical, Tax Aware and Income Distribution
Models offer investors access to varied investment styles and
objectives; however, Primerica makes no representation or
warranty that any particular investment style or Model will
be profitable, or that any style or Model is more likely than
another to achieve an investor’s objectives. Strategic Models
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individual cryptocurrencies or cryptocurrency indexes are
likewise subject to high levels of volatility.
or other identifying documents that will allow us to identify
you. This information may be shared between Primerica
and its affiliates. For additional important information,
please review our brochure titled, “What Does Primerica
Do with Your Personal Information.” Primerica reserves the
right to reject investment restrictions based on the volume,
magnitude or nature of the request.
Item 8 – Client Contact with
Portfolio Managers
• Diversification and Correlation: A fund that tracks
an index of a limited number of cryptocurrencies is not
diversified. In addition, cryptocurrency values tend to
be highly correlated, which would reduce the potential
benefits of diversification even
if the number of
cryptocurrencies tracked by an index were to increase.
Such an investment should be considered speculative and
only be considered by investors willing to bear the risk of
total loss;
• Valuation: Unlike a stock that represents an ownership
interest in a company or a fixed income security that
represents a debt owed by the issuer, cryptocurrencies
typically have no intrinsic value tied to cash flow, dividends
or tangible property.
securities designed
to
• Regulation: While
Primerica is the discretionary portfolio manager for the
Program. You may contact Primerica at the address and
telephone number listed on the cover page of this brochure.
Contact information for the overlay manager can be found in
the BNY Mellon Advisors, Inc. Form ADV brochure. Inquiries
about the Asset Managers may be directed to Primerica or to
the Asset Managers directly.
track
cryptocurrency prices are subject to U.S. regulation,
cryptocurrency itself is largely unregulated.
• Security: Due to the unregulated nature of cryptocurrency
and digital asset platforms, cryptocurrency may be more
susceptible to fraud, manipulation, security failures or
operational failures than traditional asset classes.
Each of the mutual funds, ETFs and ETPs held in your account
has one or more investment managers that manage the
fund’s investments. Generally, these investment managers
do not have direct contact with fund shareholders. Mutual
funds typically operate client service and investor relations
departments that handle shareholder communications.
Information regarding how to contact the fund is available in
the fund’s prospectus.
Additional information regarding the risks associated with
investments in cryptocurrency can be found in the fund’s
prospectus.
Item 7 – Client Information Provided to
Portfolio Managers
You may contact your Advisor in person, in writing, or by
telephone. Primerica will periodically communicate with
you by email to deliver disclosures, agreements, and other
information related to the Program, and to obtain your
electronic signature on agreements and administrative forms.
Advisors are permitted to communicate with you by email or
Firm approved text messaging to schedule appointments
or share marketing and educational information with you.
Primerica does not accept requests to buy or sell securities
sent by you via email, text or app- based messaging service.
Advisors are required to be reasonably available to Program
participants and to respond promptly to client requests for
contact. You and your Advisor may choose how often to
have discussions concerning your Program Account. For
assistance with your account or to obtain contact information
for your Advisor or an Asset Manager, contact Primerica
Advisors at (833) 786-0550 during normal business hours. For
online access to a Program Account visit https://primerica.
netxinvestor.com.
When establishing an account, you will be asked to complete
a Lifetime Investment Program Proposal and an Investment
Profile to document your financial situation, risk profile and
investment objective. You will also be given an opportunity
to place reasonable investment restrictions on your account.
Primerica Advisors will share this information as necessary
to establish and maintain your account. For model-
delivery strategies your financial information and account
restrictions will not be shared with the Asset Managers,
or with the portfolio managers of the funds held in your
Program Account. For manager-traded strategies, account
information will be shared with the Asset Manager as
necessary to manage your investments. We will also collect
general information including your name, a street address,
date of birth, and an identification number, such as a Social
Security Number. We may also ask to see your driver’s license
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Review of Accounts
Item 9 – Additional Information
Other Financial Activities and Affiliations
Annually, Primerica or your Advisor will undertake reasonable
efforts to contact you to discuss your financial situation and
investment objectives to determine whether the account
continues to meet your investment needs. Also, Primerica will
remind you periodically to contact us or your Advisor if there
have been any changes to your circumstances that would
cause you to alter your responses to the investment profile
questionnaire. The monthly statements you will receive will
show the securities held in your account, the value of the
securities and any transactions that occurred in the account
during the previous period. Primerica will monitor and adjust
Program Accounts as described in this brochure.
Client Referrals and Other Compensation
PFS Investments, Inc. is an indirect, wholly-owned subsidiary
of Primerica, Inc., a publicly traded company (NYSE – PRI)
headquartered in Duluth, Georgia. Primerica, Inc. offers
financial products and services, including term life insurance,
mutual funds, annuities, mortgage loans and other products
which are distributed through various subsidiaries. PFSI is
registered with the SEC as a broker-dealer and investment
adviser. Through its broker-dealer operations, PFSI sells
mutual funds, variable annuities, employer-sponsored
retirement plans and 529 Plans. Certain of the Models
in the Program are constructed, in whole or in part, using
mutual funds. These Models may include mutual funds that
also are available through PFSI’s broker-dealer operations.
Depending on your preferences, you may be able to meet
your investment needs by purchasing from PFSI or its
affiliates products and services other than the Program.
Before deciding how to invest, you should carefully consider
the costs and services associated with the different products
available through PFSI and its affiliates.
Code of Ethics
Primerica does not directly or indirectly compensate any
person for client referrals. Advisors are eligible for cash
bonuses. Bonuses are in addition to an Advisor’s compensation
derived from the Wrap Fee. The possibility of receiving this
additional compensation could cause an Advisor to favor
the Program over other investment options when deciding
which products to present to you for your consideration. We
mitigate this conflict as follows: (i) through our supervisory
practices, and (ii) by disclosing it to you. Before investing, you
should carefully consider the cost and benefits of the Program
along with your investment needs and objectives.
Primerica Advisors has adopted a Code of Ethics (“Code”)
pursuant to Rules 204A-1 and 204-2 of the Investment Advisers
Act of 1940. The Code is intended to reflect the principles that
govern the conduct of Primerica Advisors and its supervised
persons in those situations where Primerica Advisors acts as
an investment advisor as defined under the Advisers Act. The
Code addresses topics such as standards of business conduct,
compliance with applicable federal law and the personal
securities activities of associated persons. Primerica Advisors’
supervised persons may invest in the same securities as are
recommended to clients, at the same or different times. All
supervised persons are required to acknowledge receipt of
the Code policies. A copy of the Code is available upon request.
Advisors also participate in award and incentive programs,
in which they are eligible to receive commemorative rings
or watches, trips or other non-cash compensation based
on their securities sales. These programs are based on total
securities production, which includes sales of mutual funds,
variable annuities, index-linked variable annuities, fixed-
indexed annuities, fixed annuities, and managed accounts.
These programs provide an additional incentive for our
representatives to recommend a securities product to you
during program periods, which occur throughout a calendar
year. We mitigate this conflict as follows: (i) through our
supervisory practices, and (ii) by disclosing this conflict to you.
Referrals to BNY Wealth Management
Primerica’s supervised persons,
including your Advisor,
are permitted to invest in the Program in the same Models
they recommend to you or in different Models. Supervised
persons, including your Advisor, also are permitted to own
securities, in accounts outside of the Program, that are the
same as, similar to or different from the securities you own
in your Program Account. Primerica mitigates conflicts of
interest related to investments owned by supervised persons
through its policies and procedures and through disclosure.
Primerica has entered into an agreement with BNY Wealth
Management, an affiliate of Pershing, LLC and BNY Advisors,
under which we may from time to time introduce an investor
to BNY Wealth Management. BNY Wealth Management
offers investors who invest with them high net-worth asset
management and related services. Generally, we only
would refer to BNY Wealth Management a high-net-worth
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Program authorize Primerica to give funds and securities
disbursement and transfer instructions for the Program
Account to PBSI and Pershing and their respective agents.
Contributions to a Program Account made by check must
be made payable to Pershing. Checks received by Primerica
Advisors made payable to any entity other than Pershing will
be returned to the client or to the sender.
investor seeking services unavailable through our Program.
Primerica’s introduction is not intended to be, and should
not be considered, investment advice or a recommendation,
or fiduciary investment advice to an individual retirement
account, of any BNY Wealth Management services.
BNY Wealth Management pays compensation to us if
you enter into an advisory agreement with them as a
result of such an introduction. We typically will receive
more compensation if you enroll in the Program, because
Program investment advisory fees exceed the compensation
that would be payable to us by BNY Wealth Management,
therefore, we have a financial incentive to recommend
that you enroll in the Program rather than introducing you
to BNY Wealth Management. In connection with any such
introduction, you will receive additional information from us
or BNY Wealth Management.
Financial Information
For all Program Accounts, Primerica has authority to access
your account for the purpose of collecting advisory fees, as
described in the Fees section of this brochure. Additionally,
if you provide the qualified custodian with appropriate
written authorization, typically referred to as a standing letter
of authorization (SLOA), Primerica will have the authority
to direct the qualified custodian to distribute funds or
securities from your Program Account for delivery to a
third party. At least quarterly, you will receive an account
statement from the qualified custodian that shows the
activity in your account.
Primerica does not require or solicit prepayment of more
than $1,200 in fees per client six months or more in advance
and therefore has not included a balance sheet of its most
recent fiscal year. Primerica is not aware of any financial
condition that is reasonably likely to impair its ability to meet
its contractual commitments to clients, nor has the firm been
the subject of a bankruptcy petition at any time during the
past ten years.
You should carefully review your account statements to
ensure there are no discrepancies and that any distributions
for your account were made with your authorization. If
you are concerned that unauthorized activity has occurred
in your Program Account, you should contact Primerica at
the phone number listed on the cover page. You also have
online access to your Program Account where you can view
account activity at any time.
Custody
No Legal or Tax Advice
Neither Primerica nor its Advisors provide tax, accounting
or legal advice. You should consult with your tax advisor
regarding the tax consequences of investing assets in or
withdrawing assets from the Program. If you plan to sell
securities or other assets to fund your Program Account, you
should consider the potential for capital gains and other taxes
that may be triggered by the sale.
Pershing
is the qualified custodian who will provide
safekeeping and other services for all assets in the Program.
Accordingly, Pershing will hold all book-entry shares of the
Program assets and will process all purchases, redemptions
and other transfers of such shares. In addition, Pershing
will receive and distribute dividends and other distributions
and send you statements of all activity in your Program
Account on no less than a quarterly basis. Investors in the
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