Compliance

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Jul 13, 2007 8:01 pm

I have been a long time reader of these forums and have now decided to give up my career to start constantly posting.  I am recently independent after moving from mother wirehouse and have learned a lot from a few on here - so thanks for the good posts.


On the subject of compliance, what is the extent some of you are keeping your "cover your ass" files?  What all are you throwing into your compliance folder for when an audit occurs?


Jul 16, 2007 10:42 am
snaggletooth:

I have been a long time reader of these forums and have now decided to give up my career to start constantly posting.  I am recently independent after moving from mother wirehouse and have learned a lot from a few on here - so thanks for the good posts.


On the subject of compliance, what is the extent some of you are keeping your "cover your ass" files?  What all are you throwing into your compliance folder for when an audit occurs?



The normal stuff they want, based on your BD'scompliance manual.  In the client files, I keep anal notes on EVERY conversation I had with the client.........

Jul 16, 2007 11:51 am
bluestars80:
snaggletooth:

I have been a long time reader of these forums and have now decided to give up my career to start constantly posting.  I am recently independent after moving from mother wirehouse and have learned a lot from a few on here - so thanks for the good posts.


On the subject of compliance, what is the extent some of you are keeping your "cover your ass" files?  What all are you throwing into your compliance folder for when an audit occurs?


The normal stuff they want, based on your BD'scompliance manual.  In the client files, I keep anal notes on EVERY conversation I had with the client.........



Ditto. 


I also have clients sign a disclosure/letter when they insist on buying an investment that I have advised them not to purchase.  I do the same for long term care.  When I have made a presentation and they decide they don't need or want long term care, I have them sign.

Jul 16, 2007 12:08 pm
Dust Bunny:

I also have clients sign a disclosure/letter when they insist on buying an investment that I have advised them not to purchase.  I do the same for long term care.  When I have made a presentation and they decide they don't need or want long term care, I have them sign.


Super idea, I have not done that but NOW will..........

Jul 16, 2007 12:51 pm
bluestars80:
Dust Bunny:

I also have clients sign a disclosure/letter when they insist on buying an investment that I have advised them not to purchase.  I do the same for long term care.  When I have made a presentation and they decide they don't need or want long term care, I have them sign.


Super idea, I have not done that but NOW will..........



This actually did save my a$$ one time.  Client insisted on purchasing a rather large (for him) block of a very risky stock for which I had no research available.  The letter he signed basically stated that I had no research available for this stock, that I felt it was much too risky for his investor profile, and that I had recommended that he should not purchase the stock and that he was doing so against my advice.  I also documented in the same letter that I had attempted to get thim to put a stop loss order on the stock so that if it did drop we could minimize the losses and that he declined to do this as well.  (A real retard....not documented in the letter )  Made him sign and date and I signed and dated...gave him a copy and kept the original.


The stock eventually became worthless. When he tried to complain to the home office, I was able to show the letter and my notes regarding our conversations. 


I haven't had to use the LTC letter.....yet.  I explain to the clients why they are signing the decline.  


"This letter is to document that I have offered long term care insurance that I feel would be very important in protecting your portfolio in the event of being in a long term care situation.(Which of course we hope will NEVER happen, but who can be sure)  We have spent many years growing your investments and I would be irresponsible if I also didn't show you a way to protect your portfolio from spending down for long term care needs.  Since you are declining this opportunity, I will ask you to sign this so I can have documentation to present to your heirs and beneficiaries when they ask why I didn't protect you.   Sign here---------->" 


Jul 16, 2007 1:30 pm
Dust Bunny:
bluestars80:
Dust Bunny:

I also have clients sign a disclosure/letter when they insist on buying an investment that I have advised them not to purchase.  I do the same for long term care.  When I have made a presentation and they decide they don't need or want long term care, I have them sign.


Super idea, I have not done that but NOW will..........



This actually did save my a$$ one time.  Client insisted on purchasing a rather large (for him) block of a very risky stock for which I had no research available.  The letter he signed basically stated that I had no research available for this stock, that I felt it was much too risky for his investor profile, and that I had recommended that he should not purchase the stock and that he was doing so against my advice.  I also documented in the same letter that I had attempted to get thim to put a stop loss order on the stock so that if it did drop we could minimize the losses and that he declined to do this as well.  (A real retard....not documented in the letter )  Made him sign and date and I signed and dated...gave him a copy and kept the original.


The stock eventually became worthless. When he tried to complain to the home office, I was able to show the letter and my notes regarding our conversations. 


I haven't had to use the LTC letter.....yet.  I explain to the clients why they are signing the decline.  


"This letter is to document that I have offered long term care insurance that I feel would be very important in protecting your portfolio in the event of being in a long term care situation.(Which of course we hope will NEVER happen, but who can be sure)  We have spent many years growing your investments and I would be irresponsible if I also didn't show you a way to protect your portfolio from spending down for long term care needs.  Since you are declining this opportunity, I will ask you to sign this so I can have documentation to present to your heirs and beneficiaries when they ask why I didn't protect you.   Sign here---------->" 



Thanks...what kind of Scotch are you enjoying today?

Jul 16, 2007 2:11 pm

Well....none right now....I'm at work...  


But later  Chivas or Glenlivet.  I like Scoresby too.

Jul 17, 2007 12:11 pm
Dust Bunny:

Well....none right now....I'm at work...  


But later  Chivas or Glenlivet.  I like Scoresby too.




Both fine choices, I prefer Glenfiddich myself............