Every New Year brings feelings of nostalgia, looking back to what was and looking forward to what will be. Here in Dynamic’s Compliance department, we recognize and celebrate both the past and the future and are happy to share some of the changes coming in 2020. We look forward to another productive year and working directly with each of you!
New Solution Allows ‘Affiliates’ Greater Confidentiality
Good news for Dynamic IARs, IAR staff members and employees (“affiliates”)! In an effort to provide a greater level of confidentiality and continue to comply with SEC requirements, we’re implementing a solution that allows “affiliate” personal account Household records to be hidden in Wealth360 and Orion.
Effective Feb. 1, 2020, to accomplish this, all “affiliate” Household record ownership will be updated to show Dynamic’s Chief Compliance Officer Cherie Jolly as the “Financial Advisor.” The updated Household record will list the individual “affiliate” member relative as a Client Team member allowing the individual affiliate to continue to view their Household in Wealth360. Each Household will also be labeled as Employee/Affiliate “Type” to allow for easier filtering and reporting.
In Orion, any Household record categorized as Employee (“affiliates”) will be hidden from view to provide a greater level of confidentiality.
By making these changes, you won’t be able to link directly to your account information in Orion. You will have to go to the custodian for details on your personal accounts.
Reports and views will be affected by this change inside Wealth360 and Orion. If you currently use the “type” field as criteria in your reports and views, you will need to update those after the change. If you need help updating your reports and views, please submit a service request.
Compliance Training Program for Dynamic IARs
In lieu of the monthly training articles and quarterly attestations that were conducted in 2019, we’ll conduct The Annual Compliance Training for Dynamic IARs via a 90-minute webinar during the third quarter. There will be five time and date options from which to choose; everyone will be required to attend one. After attending, each person will complete one questionnaire and attestation to fulfill the requirement. Please watch for the schedule that will be sent out later this year.
Social Media and Website Archiving
Thank you for your patience and assistance while we move our email, website and social media archiving services to Smarsh and Versionista. We’re already finding greater efficiency in reviewing and monitoring, utilizing these outlets.
This move aligns with Dynamic’s commitment to evolve our partnerships with vendors to better deliver every aspect of the services we provide. We’ll continue to review and upgrade our vendor relationships to deliver the highest quality service standards.
2019 Gift Logs:
Make sure you have reported on the Gift Log in Wealth360 any gifts (to or from clients) that were given or received in 2019 as required per the Code of Ethics:
The Reporting Requirements include all expressions of courtesy and appreciation (gifts) given to or received from a client with a value of $1 to $249 must be documented on the Dynamic Gift Log in Wealth360. Examples include: gift certificates, fruit, flowers, food, wine, candy, etc. These requirements are per client per year.
Dynamic will be filing our annual ADV by the end of March 2020. Now is a great time to notify Compliance of any material updates and changes that may require updates to your ADV 2b. Examples include:
- Change of residential or office address – submit a General Inquiry Service Request in Wealth360
- Change of dba name – submit a General Inquiry Service Request in Wealth360
- Updates to outside business activities – submit an Outside Business Activity form in BasisCode
- Updates to products and services offered – discuss with Cherie Jolly
- Any potential Conflicts of Interest that may need to be disclosed
In addition to the Quarterly Account Verification attestation that will continue to be required, there are two upcoming attestations, both of which will be initiated in March 2020:
- Confirmation of receipt and review of the updated Code of Ethics
- Confirmation of receipt and review of the updated Policies & Procedures
(Photo: Jude Beck, Unsplash)