Hello and welcome to the Compliance Checkup for September. This month we will be reviewing the CIAA fee schedule, client account information requirements and the Annual Compliance Meeting (ACM).
Important Compliance Dates
September 30th : September 30th is the last day to complete your Annual Compliance Meeting (ACM) training. Additional info below.
October 1st :
- CIAA Fee Schedules dated October 1st or later will need to be completed for all asset levels. We will also no longer accept the “greater than” (>) symbol on fee schedules starting with paperwork dated Oct 1st or later.(see below for additional info)
- NIGO Changes: Starting October 1st work items that do not contain proper documents will be sent back to the rep office before principal review. There will be a full field announcement on October NIGO changes later this month.
November 1st: Starting November 1st work items for any client account that does not contain paperwork dated within the past 3 years will be sent back to the rep. Due to FINRA and Regal policies, all client paperwork over 3 years old will require an update. Look for a full field announcement in October with additional details.
November 1st – December 1st : This will be the renewal period for 2020 state licensing. There will be a full field announcement in late October / early November as well as individual messages to reps asking them to confirm their registrations for 2020.
February 29th 2020: Deadline by which all client account info must be up to date. This includes all clients on the RIA and BD side. Up to date is defined as having a new account form dated within 3 years or a documented letter to the client asking for updated information. There are additional details below and there will be a full field announcementin October.
CIAA Fee Schedule
All Asset Levels: Starting with paperwork dated October 1st or later we will be Nigoing CIAA fee schedules that do not contain a fee for all asset levels. Up until this point we have only required a fee for asset levels up to 1 million dollars.
The Greater Than Symbol (>): We will also no longer be allowing reps to use the greater than ( > ) symbol. This has caused confusion based on which way to properly face the symbol as well as confusion of the (>) symbol as the number 7 due to poor penmanship. Please be aware of these changes and adjust your procedures with clients accordingly. Below are 2 examples of acceptable fee schedules. Please note the second example includes account balance terminology we will no longer accept in the bottom 3 boxes.
The options for how to list all asset levels are below:
Client Account Information
Regal and Regulus both maintain a policy requiring client account information to be updated or confirmed at least once every three years. If you have client accounts that are over 3 years old, please plan on either updating the client folder with new paperwork or sending out a letter to your clients to confirm their current information. Regal will provide lists to reps detailing which client accounts are past the 3 year horizon and a form letter to send to clients if they will not be updated within the next 6 months. Once the ROSE conversion is complete and historical data is into COMET, we will be sending out field announcements as well as individual notifications to reps involved. The table below is a summary for the client account requirements as well as some best practices moving forward. Starting November 1st if the client account information is not up to date, work items for that account will be sent back to the rep unless they contain updated information. If you are meeting with clients please review what is on file before the meeting and obtain updated documents if necessary.
|Information / NAF on file is greater than 3 years old.
Letter Option: For clients who will not be in the office before February 2020, you may send a form letter provided by Regal. The rep will be responsible for inserting the current client Info, uploading a copy to COMET and mailing it out to the client. Any returned letters need to go into COMET for review and archiving.
New NAF Option: During the clients annual review, please get an updated NAF. This only applies to clients who you will meet with prior to February 2020.
|Information / NAF is less than 3 years old
|Nothing required, account is up to date. As a best practice please review client information prior to any meetings to determine if documents need to be updated.
Annual Compliance Meeting
The annual compliance meeting is underway, you will have completed or have assigned to you training modules on the Quest CE and Knowbe4 platform. The final day to complete your training is September 30th 2019, please reach out to Rose Lee (email@example.com) with any questions.
Thank you for everything you do!
This is the second reminder of the upcoming advisory fee billing for the 4th quarter 2019, October 1st – December 31st. Fees for the client accounts we bill directly on our advisory custodians will be processed between October 2 and October 7 (inclusive) with payroll transactions posting in Xtiva on October 9. You will see the direct deposit activity to your bank account on October 11. Any outstanding debit balances will be collected against this deposit amount.
Friendly reminders related to the billing:
- Please be sure all sell orders have been placed by close of market on Tuesday, October 1st by market close.
- Please note that we are now tracking those accounts where there are insufficient funds to cover the fees. In the future, should there be chronic shortfalls resulting in the duplication of efforts in fee collection, we will begin to assess penalty fees in accordance with the economics package.
Please let us know if there are any other questions related to this reminder notice by emailing firstname.lastname@example.org.