Broker Check

ASO NEWS & REMINDERS

RED FLAGS FOR MONEY LAUNDERING

If one or more red flags apply, please contact the Supervision team ASAP for assistance. 

Opening an Account or Execute a Securities/Insurance Transaction:

Client is overly concerned about the Company’s compliance w/ money laundering requirements.
Client is unconcerned about risks, commissions, or other transaction costs.
Client asks for exemptions from MMLIS’s no-cash payment policy, insists on dealing w/ only cash and cash equivalents. 
Subsequent Account Activity:

Client’s account has unexplained or sudden extensive wire activity – especially in accounts that had little or no previous activity.
Client deposits funds and immediately requests that the money by wired or transferred to a third party or another firm, w/out any apparent business purpose.
Client’s account shows an unexplained high level of account activity with very low levels or securities transactions.
*The full list of red flags can be found in Section 19.3 in the Field Compliance Manual.* 

FINANCIAL PLANNING SUPPORT

With the recent retirement of John Wallace, Financial Planning reviews/inquiries can be sent to: 
FinancialPlanning133@ffgadvisors.com

FIRM ELEMENT

Over 90% of our associates have completed the required Firm Element.

Thank you to those who’ve completed their requirements already!

**If you have not completed the required Firm Element, the final day to complete is August 16th – no exceptions.

2024 – Off Channel Communication Attestation (DUE: 9/18)

This is a requirement of everyone – regardless of contract type.
To complete, please follow these instructions. DO NOT access through the Okta MMLIS DL chicklet (technical issues).

To begin, please go to FieldNet > “Training” tab > MMLIS Distance Learning >LAUNCH Once in MMLIS Distance Learning, click on MENU > My Training > 2024 - Off Channel Communication Attestation – Field Version > August Attestation

UPDATED CSR FORM AND CHECK PROCEDURE

The UPDATED FORM must be used starting today. FAILURE TO PROMPTLY SEND CSR FORMS AND COPY OF CHECKS WILL RESULT IN DISCIPLINARY ACTION.

ANNUAL CLIENT MEETING RECORDS NOW INTEGRATED INTO A360

  • Beginning Feb. 2, use the Advisor360 CRIA Client Contact module to document annual client meetings, which will ensure that all requirements are captured and stored in Advisor360; scanned uploads will no longer be accepted after Feb. 1. Click here for more information.
  • Attend training 2/8 at 9AM EST (A133 Development Calendar Invite Sent) details here.

Annual Code of Ethics attestation and Personal Securities Accounts disclosure launches Monday 1/15/2024 via A360.

If you’re registered and/or a NRF, you are required annually to attest to the Code of Ethics and to review disclosed securities accounts. The task can be completed by logging into A360, then Practice360, and clicking on the Compliance tab. Next, click the “Code of Ethics/Personal Securities Report” link to be directed to the attestation.

SIMPLE STEPS FOR COMPLIANT BUSINESS TEXTING

  • Use only your Global Relay or Advisor360 number for business texting.
  • Update email signatures immediately and business cards before year-end.

Do Not Store Any Client Files or Other Confidential Information on One Drive

OneDrive is an excellent tool for collaboration and storing working documents but is not approved for storing client files and agency supervisory records. Four vendors are SEC and FINRA approved for storing official records: 

  • MuniMetrix for client and agency records. 
  • Laserfiche for client and agency records. 
  • Advisor360 for client records only. For help or questions, reach out to Bryan Menard.

REMINDER: GLOBAL RELAY MUST BE INSTALLED GLOBAL RELAY ON YOUR COMPUTER AND MOBILE DEVICE

ACTION REQUIRED: If you have not activated your GLOBAL RELAY Feature on your mobile phone, please make sure to do so immediately. This is a Compliance requirement and must be addressed. Use only your Global Relay or Advisor360 number for business texting. Update email signatures immediately and business cards before year-end.

Download instructions here and visit FieldNet for more resources.  If you have any questions reach out to: FFGITSUPPORT@ffgadvisors.com or ASO133@ffgadvisors.com.

IS YOUR FORM ADV PART 2B UP TO DATE?

Investment adviser representatives must promptly update information in their Form ADV Part 2B (Brochure Supplement) whenever it becomes materially inaccurate. For any advisory account (CRIA) reassigned, the new IA-rep must provide the client a copy of their Brochure Supplement within 30 days of reassignment.

  • Deliver the Brochure Supplement in person, by mail, or via DidUSign using the ADV Delivery Receipt Acknowledgement.
  • Documentation that the Brochure Supplement was provided must be maintained in the client record and should include the method of delivery (e.g., standard mail, UPS, in-person) and the date of mailing or delivery.

SOCIAL MEDIA REMINDER

Remember to keep your social media profiles connected to Hearsay Social. Connections to Hearsay routinely break due to security settings, and require manual action on your part to reconnect. Please reach out to the ASO team for help with connecting/re-connecting to Hearsay Social. 

EXPIRED WEBSITES

If you have a website for business, please make sure to keep track of when the site is up for re-approval. Websites with expired approvals are considered unapproved, and may need to be put “Under Construction” until brought back into compliance. The year and month of expiration appear as the first six digits in the Compliance Reference Number (CRN); Example: CRN202301-XXXXXX indicates expiration at the beginning of January 2023. 

RIGHTBRIDGE PROFILER

Remember to download the RightBridge Profiler report after running, and save it in the documents section of Client360; saving the RightBridge report to C360 is a requirement.

COMPLIANCE QUICK LINKS

Click the image to go to the link. You must be logged in to OKTA to access these resources.

MML Investors Services Resource Centers

Click the button below for a more robust collection of Training Replays, Instructional Videos and Best Practice Tutorials designed to help you effectively conduct investment business.

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