Hello! We hope that you are enjoying the Jingle Bell Trivia this year. Julie and I had fun writing the questions and answers. We can't wait to give out the prizes in 2 weeks! Yesterday's question was a hum-dinger with a lot of disparity in responses received on the blotter question. So, we thought we should send out a Compliance Alert to provide further clarification as this appeared to be a confusing area for offices. Additionally, we wanted to notify you about a change in the blotter process starting January 2017 as well.
Starting in January, you should no longer send the blotters to Compliance as Operations will receive and review the blotters. If you do not use Docupace,
please email them weekly (or monthly if you do not receive many checks) to Michelle Hancock or fax them to 217-469-5004 or 217-233-5709. Furthermore, as part of our FINRA audit, we were asked to amend our WSP section on blotters. Therefore,
attached are the applicable changes to the WSP, which are highlighted.
For some background on this subject, the SEC requires that blotters (checks and securities received) be kept containing an itemized list of all direct
business transactions, checks received and physical certificates received in branch offices. The blotters must be kept for 3 years, 2 years in an easily
accessible place. The Checks Received Blotter and Securities Received Blotter also have been updated.
If you do not have Docupace, you are given a choice of when to send check blotters to Operations. You may send them weekly or monthly. If you do not receive any checks in a week, then write NONE across the blotter, complete the info on the blotter and send it to Operations. The other option is to just send a monthly check blotter to Operations. Same process as the weekly blotter, if you receive no checks in the month then write the words NONE across the blotter, complete the
info required on the blotter and send it to Operations by the 5th day of the following month. If you do receive a check, then complete the
information requested and send the blotter to Operations. Copies of the checks that you received in your office, must also be attached to the blotter.
A securities blotter is not a weekly requirement, it is only sent when you receive a physical certificate. As with the check blotter, a copy of the stock certificate must be attached to the blotter and forwarded to Operations as well.
If you are a Docupace user, you can use Docupace to capture the checks if you list the Client Document Type as a Check and scan it separately from any
other documents being scanned (i.e. DO NOT SCAN THE CHECK IN WITH AN APPLICATION, SCAN IT SEPARATELY WITH CLIENT DOCUMENT TYPE AS CHECK).
We ask for your compliance with this process as we are only able to run a check blotter from Docupace by pulling a report for document types listed
as Check. If you have questions, please contact Michelle Hancock for further information.
Checks and Securities Received Blotter - WSP Section Highlighted