Purchasing mutual funds through Ameriprise Financial

Payments from Product Companies

Ameriprise Financial Services receives a variety of payments for selling the products of proprietary and non-proprietary product companies. These payments include payments for marketing support, recordkeeping and other client account services, start up costs, technology and related expenses, conferences and client events. The most significant payments are marketing support payments.

Mutual fund and 529 Plan Marketing Support Payments

Mutual fund and 529 Plan marketing and sales support payments are received from certain mutual fund firms (described below as "Full" and "Limited" participation firms),(the "Program"), within the more than 220 mutual fund firms ("firms") Ameriprise Financial Services offers.

The goal at Ameriprise Financial Services is to offer a wide range of mutual funds using the following criteria:

• Marketing payments to support the cost of distribution
• Financial strength of the firm
• Product breadth and strong performing funds
• Ability to provide wholesaling and training to Ameriprise Financial advisors
• Tax benefits offered by individual states (specific to 529 Plans)
• Overall quality of the 529 Plan (specific to 529 Plans)

Ameriprise financial advisors may offer, and clients are free to choose, mutual funds from the more than 220 firms offered. However, certain aspects of the Program may create a conflict of interest or incentive if Ameriprise Financial Services promotes, or Ameriprise financial advisors recommend, the mutual funds offered by a firm participating in the Program versus mutual funds offered by nonparticipating firms. In addition, among firms participating in the Program, advisors generally have a greater incentive to offer mutual funds from Full Participation Firms than mutual funds from Limited Participation Firms. As further described below, these conflicts and incentives may arise from the marketing and sales support provided to our financial advisors by, as well as the payments Ameriprise Financial Services receives from, firms participating in the Program, and with other relationships with firms, including our affiliation with the RiverSource Investments and the RiverSource mutual funds.

Marketing and sales support

The firms in the Program that are Full Participation Firms provide education, training, marketing and sales support to Ameriprise financial advisors. These firms may reimburse Ameriprise Financial Services, or Ameriprise financial advisors, for client/prospect education events and advisor sales meetings, seminars, and training events consistent with Ameriprise Financial Services policies; Ameriprise Financial Services may also receive nominal non-cash benefits from time to time. Limited Participation Firms pay marketing support at a lower level than Full Participation Firms; therefore, Limited Participation Firms may not provide some services, or the same level of services, to Ameriprise financial advisors. As a result, Ameriprise financial advisors may have a greater familiarity with Full Participation Firms.

Marketing support payments

To be included in the Program, firms have agreed to pay Ameriprise Financial Services a portion of the revenue generated from the sale and/or management of mutual fund shares. Full Participation Firms pay marketing support at a higher level than Limited Participation Firms. Each year a client holds shares of a particular mutual fund, the mutual fund's advisor or distributor may pay to Ameriprise Financial Services an amount based on the value of the mutual fund shares held in clients' accounts (asset-based payment). In addition, a mutual fund's advisor or distributor may pay a fee to Ameriprise Financial Services for the mutual fund shares purchased during a given period (sales-based payment). As of December 2008, Ameriprise Financial Services received an asset-based payment (up to 0.25% per year for mutual funds and 0.16% per year for 529 Plans) on some or all of Ameriprise Financial Services clients' assets managed by the participating firms and a sales-based payment (up to 0.25% for both mutual funds and 529 Plans) on some or all of the participating firms' gross sales made through Ameriprise Financial Services. Limited Participation Firms generally limit by prospectus the amount of marketing support their affiliates may pay on mutual funds. In 2008, Ameriprise Financial Services had an arrangement with a firm for its money market fund sweep program for which Ameriprise Financial Services received marketing support payments of up to 0.92%. Currently, Ameriprise Financial Services receives 0.62% for the above referenced money market fund sweep program. Specific marketing support payments are detailed in "An Investor’s Guide to Purchasing Mutual Funds" and "Purchasing Mutual Funds at Ameriprise", which may be viewed at the Ameriprise Financial website www.ameriprise.com/funds. These arrangements vary between firms and may be subject to change or renegotiation at any time. If a firm ceases to pay marketing support or other fees, Ameriprise Financial Services may remove the firm from the Program and may cease to offer mutual fund shares and/or 529 Plan(s).

Full Participation

Twenty-three firms fully participate in the Program. These firms include the RiverSource mutual funds (the Ameriprise Financial-affiliated fund family that is discussed below), American Century, BlackRock, Calvert, Columbia, Credit Suisse, Dreyfus, DWS Scudder, Eaton Vance, Evergreen, Federated, Fidelity, Goldman Sachs, Invesco Aim, Janus, John Hancock, Legg Mason, MFS, Nuveen, Oppenheimer, Van Kampen, Virtus (formerly Phoenix) and Wells Fargo. These firms are referred to as "Full Participation Firms." We offer 529 Plans from 15 firms. Of those 15 firms, 11 are Full Participation firms. These fund firms include American Century, Calvert, Columbia, Fidelity, Invesco Aim, John Hancock, Legg Mason, MFS, Oppenheimer, Van Kampen and Wells Fargo. Each of these firms is referred to as a "Full Participation Firm."

Limited Participation

Four firms participate in the Program at a limited level. These firms include Alliance Bernstein, Allianz/PIMCO, Franklin Templeton and Putnam. These firms are referred to as "Limited Participation Firms." 529 Plan "Limited Participation Firms" include Franklin Templeton, Putnam, Upromise (for whom we offer two 529 plans), and American Funds (whose plan is offered to Virginia residents only). American Funds does not pay marketing support to Ameriprise Financial Services.

From time to time, Ameriprise Financial Services may enter into new relationships with firms that do not currently participate in the Program. Generally, Ameriprise Financial Services will only add firms to the Program that satisfy the criteria for Full Participation. See the website at www.ameriprise.com for the most current Program information.

Mutual fund list

Ameriprise financial advisors may make mutual fund recommendations based on a group of mutual funds that appear on an Ameriprise Financial Services mutual fund list ("List"). Morningstar Associates, LLC developed the List using quantitative and qualitative criteria. Approximately 1300 mutual funds are eligible for inclusion on the List, which consists of only RiverSource mutual funds and mutual funds of Full Participation Firms in the Program described above. In developing the List, Morningstar Associates applies a quantitative and qualitative evaluation process that includes an analysis of a mutual fund’s return, risk and expense; the tenure of its portfolio managers; and the consistency of its performance and style. Certain mutual funds that would have otherwise been included on the List are excluded due to high investment minimums. Ameriprise financial advisors and clients must consider suitability, breakpoint discount eligibility, and Net Asset Value (NAV) transfer availability when trading mutual funds. The mutual funds on the List are subject to change periodically; however, changes to the List should not be the sole reason that prompts mutual fund trading. The List was developed by evaluating the characteristics of Class A mutual fund shares. As a result, clients for whom another share class may be more advantageous may be unable to purchase a mutual fund on the List if the mutual fund firm does not offer that particular share class. In addition, the List was developed using the share class of the mutual funds currently available through Ameriprise^® Strategic Portfolio Service (SPS) Advantage or Ameriprise^® Brokerage. As a result, clients may not be able to purchase a mutual fund on the List if that share class is not available through the product or service in which the client invests. Ameriprise Financial Services receives payments for services provided by Full Participation Firms and the RiverSource mutual funds. The amount of fees Ameriprise Financial Services receives from firms eligible for inclusion on the List is not considered in the List selection process. Firms do not pay Ameriprise Financial Services to be included on the List. Clients may choose to follow the recommendations provided by their Ameriprise financial advisor or may select from any other mutual fund offered through Ameriprise Financial Services regardless of whether that mutual fund appears on the List.

Other Distribution Support relationships

Ameriprise Financial Services also has arrangements with firms for distribution support services. These services support the distribution of the fund's shares by making them available on one or more of Ameriprise Financial Services' platforms, commonly known as "shelf space." These mutual fund firms do not provide marketing and sales support to Ameriprise financial advisors and do not participate in the mutual fund list.

Other financial relationships

In addition to sales charges, 12b-1 fees, and marketing support payments Ameriprise Financial Services receives, the mutual fund’s advisor, distributor, or affiliate may also make other payments to Ameriprise Financial Services for client services and other account maintenance activities provided. Information about these charges and fees may be viewed at www.ameriprise.com/funds in the document titled "An Investor's Guide to Purchasing Mutual Funds through Ameriprise Financial" or in the mutual fund prospectus. Ameriprise Financial Services receives up to 0.40% per year on some, or all, Ameriprise Financial Services clients' assets managed by participating mutual fund firms.

Ameriprise Financial Services provides clients with access to other firms through its relationship with Charles Schwab & Co., Inc. ("Schwab") and Schwab's mutual fund program. Schwab passes to Ameriprise Financial Services certain payments it receives from firms accessed through its program. American Enterprise Investment Services, Inc., an affiliate of Ameriprise Financial Services and its clearing firm, receives payments from some firms for distribution support, client and other account services. AEIS shares a portion of that fee with Ameriprise Financial Services for providing distribution support services, which is sometimes referred to as shareholder support services.

Ameriprise Financial Services and its affiliates may have other relationships with firms whose mutual funds Ameriprise Financial Services offers. These relationships may include affiliates of firms acting as a sub-advisor to RiverSource Investments or affiliates of a firm managing an investment portfolio within another Ameriprise Financial or RiverSource product, such as a variable annuity. Firms may use RiverSource Investments as an underlying investment option in products offered through the Program.

Transaction charges

Ameriprise financial advisors pay charges on mutual fund sells, purchases, and exchanges ("Transaction charges"). Transaction charges are determined using a variety of factors such as the type of transaction, processing methodology (e.g., online, telephone, systematic arrangements), account type (fee-based SPS Advantage account/transaction-based brokerage account), and, in one case, the firm. Ameriprise financial advisors pay the same mutual fund transaction rate for all mutual fund firms except American Funds. Ameriprise financial advisors pay significantly higher transaction charges (up to $85 per transaction) on mutual fund purchases of American Funds. This higher transaction charge may be a disincentive for Ameriprise financial advisors to recommend American Funds. Additionally, American Funds does not pay Ameriprise Financial Services for marketing support.

RiverSource mutual funds

RiverSource Investments, LLC sponsors and manages the RiverSource family of mutual funds (which includes "Seligman" and "Threadneedle" branded mutual funds). RiverSource Fund Distributors, Inc. is the principal underwriter and distributor of the RiverSource family of mutual funds. The affiliates of Ameriprise Financial Services provide certain administrative and transfer agent services to these mutual funds. Ameriprise Financial Services and its affiliates generally receive more revenue from sales of RiverSource mutual funds than from sales of other mutual funds. Employee compensation and operating goals at all levels of the company are tied to the company's success. Certain employees may receive higher compensation and other benefits based, in part, on assets invested in the RiverSource family of mutual funds.

Summaries of 2008 mutual fund firms’ marketing support follow, segmented by mutual fund or 529 products:

Mutual Fund Marketing Support Arrangements by Fund Firms: January 1, 2008-December 31, 2008

Fund Firm	Total Marketing Support Payments from Fund Firm in 20081	Source of Payment
AllianceBernstein	$820,297	AllianceBernstein Investment Research and Management, Inc.
Allianz/PIMCO	$1,547,878	Allianz Global Investors Distributors LLC
American Century	$5,268,040	American Century Investment Services, Inc.
BlackRock2	$62,227	BlackRock Advisors, LLC
Calvert	$4,319,013	Calvert Distributors, Inc.
Columbia	$8,765,379	Columbia Management Distributors, Inc.
Credit Suisse	$387,864	Credit Suisse Asset Management Securities, Inc.
Dreyfus	$2,622,651	The Dreyfus Corporation and/or Dreyfus Service Corporation
DWS Scudder	$1,351,300	Scudder Distributors, Inc.
Eaton Vance	$5,594,585	Eaton Vance Distributors, Inc.
Evergreen	$1,528,166	Evergreen Investment Services, Inc.
Federated	$329,498	Federated Securities Corp.
Fidelity	$11,401,602	Fidelity Distributors Corporation
Franklin Templeton	$4,120,720	Franklin Templeton Distributors, Inc.
Goldman Sachs	$1,902,742	Goldman, Sachs & Co.
Invesco Aim3	$4,406,897	Invesco Aim Distributors, Inc.
Janus	$3,467,051	Janus Capital Management, LLC
John Hancock	$2,685,251	John Hancock Funds, LLC
Legg Mason Partners	$895,171	Legg Mason & Co, LLC
MFS	$7,855,140	MFS Fund Distributors, Inc.
Nuveen	$155,556	Nuveen Investments
Oppenheimer	$14,250,630	Oppenheimer Funds Distributor, Inc.
Putnam	$1,202,008	Putnam Retail Management Limited Partnership
Reserve	$34,212	Resrv Partners, Inc.
RiverSource	$57,541,772	RiverSource Distributors, Inc.
Van Kampen	$4,688,296	Van Kampen Funds Inc.
Virtus4	$409,033	Virtus Investment Partners, Inc.
Wells Fargo Advantage	$3,953,070	Wells Fargo Funds Distributor, LLC
Total Marketing Support Payments from Fund Firms in 2008:	$151,566,048

529 Plan Marketing Support Arrangements by Fund Firms: January 1, 2008-December 31, 2008

Fund Firm	Total Marketing Support Payments from Fund Firms in 2008¹	Source of Payment
American Century	$54,593	American Century Investment Services, Inc.
Columbia	$326,880	Columbia Management Distributors, Inc.
Fidelity	$604,249	Fidelity Investments Institutional Services Company, Inc.
Invesco Aim²	$14,208	Invesco Aim Distributors, Inc.
John Hancock	$10,182	John Hancock Funds, LLC
MFS	$47,633	MFS Fund Distributors, Inc.
Oppenheimer	$110,641	Oppenheimer Funds Distributor, Inc.
Putnam	$20,662	Putnam Retail Management Limited Partnership
Upromise	$398	Upromise Investments, Inc.
Van Kampen	$45,107	Van Kampen Funds Inc.
Wells Fargo Advantage	$856,763	Wells Fargo Funds Distributor, LLC
Total Marketing Support Payments from Fund Firms in 2008:	$2,091,318