DWS Distributors, Inc., has adopted an Incentive Plan (Plan) covering wholesalers that market shares of the DWS funds to financial representatives (DWS Wholesalers). These financial representatives in turn may recommend that investors purchase shares of a DWS fund. The Plan is an incentive program that combines monthly and quarterly incentive components - based on achieving certain sales and other performance metrics. Under the Plan, DWS Wholesalers will receive a monetary monthly incentive based on the amount of sales generated from their marketing of the funds, and that incentive will differ depending on the product tier of a fund. Each fund is assigned to one of three product tiers - taking into consideration, among other things, the following criteria, where applicable:
This information and other factors are discussed with senior representatives from various groups within the asset management division, who review on a regular basis the funds assigned to each product tier described above, and may make changes to those assignments periodically. No one factor, whether positive or negative, determines a fund’s placement in a given product tier; all these factors together are considered, and the designation of funds in a particular tier represents management’s judgment based on the above criteria. In addition, management may consider a fund’s profile over the course of several review periods before making a change to its tier assignment. DWS Wholesalers receive the highest compensation for Tier 1 funds, successively less for Tier 2 funds and successively less for Tier 3 funds. The level of compensation among these product tiers may differ significantly.
In the normal course of business, DWS will from time to time introduce new funds into the DWS family of funds. As a general rule, new funds will be assigned to the product tier that is most appropriate to the type of fund at the time of its launch based on the criteria described above. As described above, the fund tier assignments are reviewed periodically and are subject to change.
As part of the quarterly incentive component, sales of certain funds may provide more credit toward the achievement of sales goals than other funds. The prospect of receiving, or the receipt of, additional compensation by a DWS Wholesalers under the Plan may provide an incentive to favor marketing funds in higher payout tiers or that provide additional sales credit over funds in lower payout tiers or that do not provide additional sales credit. The Plan, however, will not change the price that investors pay for shares of a fund. The DWS Compliance Department monitors DWS Wholesaler sales and other activity in an effort to detect unusual activity in the context of the compensation structure under the Plan. However, investors may wish to take the compensation structure into account when considering purchasing a fund or evaluating any recommendations relating to fund shares.
Product tiering structure