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Regulatory Reporting 28
Procedure 28

Record Retention Requirements 29
Corporate Records 29

Trade Errors 30

Training 31

Advisory Agreement 32
Procedure 32

Customer Complaint Policy 33
Procedure 33

Client Account/Correspondence/Transaction Review Policy 34
Correspondence 34
Transactions and Account Review 34

Handling of Customer Funds – Custody Issues 35
Definition 35
Policy 35
Direct Fee Deduction 35
Disbursement Authority 35
Trustee/Executor/Power of Attorney for Advisory Client 36
Qualified Custodian 36
Receipt of Funds or Securities 36

Account Valuation and Billing 37

Advisor Representative Registration, Hiring, and Training 38
Procedure 38

Theft Prevention 39
Procedure 39

Diminished Capacity & Elder Financial Abuse Policy 40
Diminished Capacity 40
Elder Financial Abuse 40
Firm Policy 40

ERISA 42
Procedure 42

Anti-Money Laundering 43
Anti-Money Laundering (AML) Policy 44
Anti-Money Laundering Program 44
Anti-Money Laundering Program Compliance Officer Appointment 44
Client Identification and Verification 44
Clients Who Refuse to Provide Information 44
Verifying Information 44
Lack of Verification 45
Recordkeeping 45
Monitoring Accounts for Suspicious Activity 45
Emergency Notification to the Government by Telephone 45
Responding to Red Flags 45
Money laundering “red flags” include 46
Responsibility for AML Records and SAR Filing 46
Training Programs 47
Giving AML Info to Fed Law Enforcement Ag and Other Fin Inst 47
Checking the Office of Foreign Assets Control (“OFAC”) List 47
Suspicious Transactions and BSA Reporting Filing a Form SAR-SF 48
SAR-SF Maintenance and Confidentiality 48
Responsibility for AML Records and SAR Filing 49
Approval & Signatures 49

Anti-Insider Trading Policy 50