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Compliance Alert - Best Practice Reminders for Consolidated Account Statements
12/20/17 /
As part of wrapping up our 2017 FINRA exam for Investment Planners, I want to provide a recommendation that we received relative to Consolidated
Account Statements as stated inFINRA Regulatory Notice 10-19for
those that create your own consolidated statements for clients. If you have any questions on these recommendations, please let me know. Thanks,
Renee
FINRA is recommending, if applicable, the following disclosures be added to any Consolidated Account Statements when given to clients (remember
the reports must be uploaded to Docupace for Correspondence Review/sent to Compliance for review):
the names of the entities providing the source data or holding the assets, their relationship with each other (e.g., parent, subsidiary or affiliated
organization) and their respective functions (introducing/carrying brokerage firms, fund distributor, banking/insurance product providers,
etc.);
a statement clearly distinguishing between assets held or categories of assets held by each entity included in the consolidated report;
the customer's account number and contact information for customer service at each entity included in the consolidated report; and
if the consolidated report provides aggregate values for several different assets, an explanation of how the aggregated values of the different
types of assets were arithmetically derived from separate asset totals.