Hello and welcome to the Compliance Checkup for November. This month we will be discussing the requirements for the Three (3) Year New Account Form updates and how advisors will be asked to make sure their client’s accounts are up to date. Please be aware that this process has been updated since we first notified the field.
Three Year NAF Update
As we complete the conversion of data from our legacy document storage system ROSE to COMET, we will begin to update client account information to reflect the requirements of FINRA rule 4512 and SEC rules 17a-3 and 17a-4. In order to make sure all relevant records are up to date we will be reaching out to our affiliated representatives with clients involved to determine how they would like to handle the client communications. There will be two options, please review them and be aware of which option will be best for each of your clients involved.
Once this project is complete for all accounts greater than three years old, Regal will send out monthly mailers (emails for clients with e-delivery) to clients whose information has crossed the 36 month threshold. As we reach out to reps involved, we will be asking them to notify their clients to expect communications from Regal regarding their account information. Starting with paperwork dated November 18th or later, we will no longer accept work items involving accounts that do not have up to date NAFs. These work items will be sent back to reps under the “insufficient paperwork” code. Please make sure you are reviewing the existing paperwork on file before meeting with clients to determine if a new NAF is required.
Paper NAF: Regal sends the client a new NAF with the information we have on file. The client would then mark any changes and send the NAF back to Regal for processing. There will be a letter of instruction included with the NAF.
eSignature NAF: Regal uses the new eSignature platform to send the NAF electronically to the client. They would then be able to eSign the document. This will only apply to clients who have consented to the E-delivery of documents.
Important Compliance Dates
November 11th : This is the date that Regal will receive renewal information from FINRA for 2020 state licensing. Further information on renewals and state additions or subtractions for 2020 will be passed along to reps the week of the 18th.
Paperwork dated November 18th or later: Work items for existing clients dated 11/18/19 or later, that do not have up to date NAFs on file, will be sent back to reps under the “insufficient paperwork” code. Please plan for you upcoming client reviews accordingly.
December 1st : State and Branch Registration changes for 2020 are due back to Regal.
If you have any questions please reach out to Ben Westin (firstname.lastname@example.org) or Abigail Morgan (email@example.com).
Thank you for everything you do!
The Compliance Team