ADVISOR TRANSITION GUIDE TRANSFERRING YOUR BROKER/DEALER AFFILIATION TO HD VEST

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1 ADVISOR TRANSITION GUIDE TRANSFERRING YOUR BROKER/DEALER AFFILIATION TO HD VEST

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3 WELCOME TO HD VEST We re happy to have you join our growing family of more than 4,500 Advisors. 1 We ve worked hard to build a competitive model that is focused on you from the moment you join our family and throughout each of your momentous accomplishments. We ve developed this guide with you in mind. Our main goal during the beginning stages of your transition is to help you transfer your business to HD Vest as smoothly as possible. In this guide, you will find detailed policies and procedures that will come in handy throughout your transition period. We ll cover everything from transferring your licenses to our wide array of technology tools, which will all help you run your business effectively and efficiently. At the end of this guide, you will find an easy-to-understand transition timeline you may use to navigate the steps of your transfer, as well as a list of frequently asked questions. Having successfully helped thousands of Advisors join HD Vest, we are ready to address all aspects of your business to ensure a timely and seamless transfer. 1 As of January 1, TRANSFERRING WITH EASE - TRANSITION SPECIALIST TEAM We understand that when transitioning your practice to a new broker/dealer, you need a partner focused on your success. Having successfully helped thousands of Advisors make the move, we have developed a dedicated team and approach to help you along the way. Our Transition Team will be focused on your Day One activities, account paperwork and introducing you to your new broker/dealer platform. They are supported by a team of skilled specialists across a variety of products, back-office processes and can provide general paperwork information. Our transition model brings you two areas of expertise: Our dedicated transition specialists will focus on all the paperwork and client account transfers. Transition Specialists Contact Information: Gene Woodard (866) , option 1, x6330 David Rosa (866) , option 1, x6549 Just as important is post account transition, and our transition consultant will work with you on all the tools and support available at HD Vest. Transition Consultant Contact Information: Heather Gantt (866) , option 1, x6411 Our goal is to ensure you have confidence and the knowledge to be able to focus on your clients and growing your practice with your HD Vest partnership. 1

4 TABLE OF CONTENTS STEP ONE PRIOR TO LEAVING YOUR CURRENT BROKER/DEALER Broker Protocol and Your Responsibilities STEP TWO TRANSFERRING YOUR LICENSE(S) General FINRA Licenses Insurance Licenses Advisor Number Assistant Licenses STEP THREE TRANSFERRING YOUR CLIENT ACCOUNTS Accounts Held Directly with Product Sponsors Account Record Change Form and Mutual Fund Application Form Annuities A Word about Variable Annuities and Variable Life Brokerage Account Transfers to First Clearing Consolidating Outside Fund Positions into First Clearing Advantage Check Writing Mutual Fund Periodic Investments and Systematic Withdrawals Tips to Guide You Through ACATs and Non-ACAT Transfers Reviewing Client Accounts Before the Transfer Proprietary and Non-Transferable Products Margin Requirements Account and Mutual Fund Coding Timing Your Account Transfers Trail Commissions from Accounts Held Directly at Product Sponsors Trail Commissions from Positions Held in Brokerage Accounts STEP FOUR ESTABLISHING YOUR PRESENCE Branch Office Identification Guidelines Retail Communication with the Public Business Cards and Letterhead Disclosures

5 Advertising Compliance Submission Process Communication Correspondence Correspondence Communication Standards Best Practices The Correspondence Review Process Client Notification STEP FIVE TECHNOLOGY VestWizard TM Account Setup and Processing (ASAP) Brokerage Maintenance Reports Customer Service Log (CSL) Trade Management Tool (TMT) Integrated Broker Workstation (IBW) Vest360 TM VestView TM VestVision TM HDVDocs Report Center APPENDIX ONE Transition Timeline APPENDIX TWO Frequently Asked Questions APPENDIX THREE Client Notification Letter Customer Account Transfer Form HD Vest Account Record Change Letter of Instruction Brokerage Account Application HD Vest Mutual Fund Account Application HD Vest Equity Indexed Annuity Disclosure Form HD Vest Insurance Purchasing/Exchange Disclosure (IPED) for Variable Annuities

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7 STEP ONE PRIOR TO LEAVING YOUR CURRENT BROKER/DEALER BROKER PROTOCOL AND YOUR RESPONSIBILITIES Before you resign from your current broker/dealer, you should be aware that HD Vest has signed on to The Protocol for Broker Recruiting (Protocol). The Protocol is an agreement among signatory firms that addresses the transfer of information and solicitation of clients when a registered representative (RR) changes firms. If the firm you are leaving is also a Protocol firm, you can take limited information and notify former clients of your move, if certain specific procedures are followed. We put together a list of frequently asked questions that describe the operation, procedures and specific conditions of taking Client Information according to the Protocol, as it pertains to transferring Advisors. Q: What is the principal goal of the Protocol? A: The Protocol helps to further the clients interest of privacy and freedom of choice in connection with the movement of their RR between firms. Q: If complied with, what benefit does the Protocol confer? A: The Protocol helps RRs and their new firm avoid litigation and potential monetary liability if they follow the procedures and limitations specified in the Protocol. Q: When RRs move from one firm to another and both firms are signatories to the Protocol, what may the RRs take? A: Only the following account information related to clients they sourced while at the firm (Client Information): 1. Client name 2. Address 3. Phone number 4. address 5. Account title Q: Are they prohibited from taking anything else? A: Yes. RRs are prohibited from taking any other documents or information. 5

8 Q: When RRs resign, what must they do? A: Resignations must be in writing, delivered to local branch management and must include a copy of the Client Information that the RR is taking with him or her and a list of clients the RR sourced while at the firm. Q: Could the RR s list of clients provided to the manager differ from what they can take with them? A: Yes. The RR s list delivered to the branch must include the account numbers for all clients serviced by the RR (whether or not the RR is taking the Client Information). The local branch management will send the information to the firm s back office. Q: What if the departing firm does not agree with the RR s list of clients? A: The RR will still be deemed as compliant with the Protocol, as long as the RR exercised good faith in assembling the list and substantially complied with the requirement that only Client Information related to clients he or she serviced while at the firm be taken. Q: What is HD Vest permitted to do with the Client Information brought over by its new RR? A: HD Vest will limit the use of the Client Information to the RR providing notification that he or she has changed firms. HD Vest will not permit the use of the Client Information by any other RR or for any other purpose. If a former client indicates to the RR that he/she would like the prior firm to provide account numbers or other account information to HD Vest, the former client will be asked to sign a standardized form authorizing the release of the information to HD Vest. Q: If the Protocol is complied with, how soon is the prior firm required to provide the new firm with information? And what information is required to be provided? A: The prior firm will forward HD Vest the client s account numbers and/or most recent account statements or information concerning the account s current positions within one business day, if possible, but in any event, within two business days of its receipt of the signed authorization. This information will be transmitted electronically or by fax and the requests will be processed by the central back office rather than the branch where the RR was affiliated. A client who wants to transfer his/her account only needs to sign an ACAT form. Q: If RRs comply with the Protocol, what can they do with their clients? A: They are free to solicit customers who they serviced while at their former firms, but only after their registration with HD Vest is effective. A firm would continue to be free to enforce whatever contractual, statutory or common law restrictions exist on the solicitation of customers to move their accounts by a departing RR before he or she has left the firm. Q: Is there any customer information that the departing RR can provide his/her new potential employer before resigning? A: Yes. It is not a violation of the Protocol for an RR to provide another firm with general information related to the RR s business prior to his or her resignation. As long as that information does not reveal client identity or client confidential information it is not a violation of the Protocol. 6

9 Q: What if, as is often the case at large firms, the RR is a member of a team or a partnership? How does that affect the implementation of the Protocol? A: If an RR is a member of a team or partnership and the entire team/partnership does not move together to another firm, the terms of the team/partnership agreement will govern: 1. the taking of client information 2. which clients the departing team members or partners can solicit. In no event, however, shall a team/partnership agreement be construed or enforced to prevent an RR from taking the Client Information for the clients he or she introduced to the team or partnership or from soliciting such clients. In the absence of a team or partnership written agreement on this point, the following terms shall govern where the entire team is not moving: 1. If the departing team member or partner has been a member of the team or partnership in a producing capacity for four years or more, the departing team member or partner may take the Client Information for all clients serviced by the team or partnership and may solicit those clients to move their accounts to the new firm without fear of litigation from the RR s former firm with respect to such information and solicitations. 2. If the departing team member or partner has been a member of the team or partnership in a producing capacity for less than four years, the departing team member or partner will be free from litigation from the RRs former firm with respect to client solicitations and the Client Information only for those clients who he or she introduced to the team or partnership. If your firm is not part of the Protocol, then the Protocol does not apply. If you have a non-compete agreement or confidentiality agreement with your current broker/dealer, please disclose this information immediately to HD Vest and send a copy of the agreement to your Business Development Consultant. These agreements and any implications that might affect your transfer must be discussed with our Compliance and Business Development departments in advance to avoid complications in registration and in transferring business. 7

10 STEP TWO TRANSFERRING YOUR LICENSE(S) GENERAL If you have had any complaints, disciplinary action or other disclosable events that require a yes answer on Form U-4, you must disclose all relevant information in advance to HD Vest and provide documentation regarding these matters. This disclosure will make it easier for us to process your application materials, which must contain reference to these matters. If you provide investment advisory services, please discuss this with your Business Development Consultant in advance, so that we can provide necessary licensing instructions and support services to transition your business to HD Vest s Registered Investment Adviser (RIA), HD Vest Advisory Services SM. Please submit your completed application to HD Vest at least four weeks prior to transfer, so we can ensure that everything is in good order. For Registered Representatives: HD Vest Transfer Application Fingerprinting should be completed via the Business Information Group system Promised payout application with copies of commission statements, if applying for a promised payout For Investment Adviser Representatives: HD Vest Investment Advisor Representative Application APPLICATION SUBMISSION PROCESS Your application can be submitted to your Business Development Consultant s attention via: Fax (972) Mail businessdevelopment@hdvest.com HD Vest Financial Services Attn: Business Development Consultant s Name 6333 N. State Highway 161, Fourth Floor Irving, Texas FINRA LICENSES Whenever possible, HD Vest uses the Temporary Agent Transfer (TAT) system to transfer a license. TAT is an electronic transfer of your FINRA and state securities licenses that clears you to do business, usually within 48 to 72 business hours. TAT allows for the automatic electronic registration and licensing of individuals with Self-Regulatory Organizations (SROs) or jurisdictions with whom they have held a registration within the past 30 days. If your previous registration terminated more than 30 days ago, the registration will need to be manually reviewed by FINRA. 8

11 HD Vest monitors your registration and will alert you to any unusual complications. We will contact you once your registration is approved. You may not engage in any client solicitation or transactions as an HD Vest Advisor until HD Vest notifies you that your licensing has been completed. Also, you may not service any accounts in states where you remain unlicensed until new licenses are granted. INSURANCE LICENSES HD Vest Insurance Agency, LLC has selling agreements with numerous top-quality insurance companies. To transfer your current insurance appointments over to HD Vest, you must first be released from your current appointments and then be reappointed through HD Vest. Insurance Licensing with each company is crucial, as timing varies from company to company and state to state. Please feel free to contact our Insurance department at (866) , option 1, x4040 with questions regarding insurance products. Contact our Insurance Licensing department at (866) , option 1, x4609 with questions regarding appointments and insurance licenses. Variable annuity and life providers ordinarily only accept the broker/dealer change on accounts once the securities license transfer has been approved in writing by FINRA, and the appointment paperwork has been received and approved at the companies. ADVISOR NUMBER Once licensed with HD Vest, you will be assigned an Advisor number, which entitles you to process orders. HD Vest cannot assign you a number until FINRA licensing has been completed. Your Business Development Consultant will notify you when you have been approved. ASSISTANT LICENSES If you are bringing assistants with you the following must take place: Registered Income Producing Assistants These individuals will be required to go through the same application process as you. This will need to be done simultaneously with you to ensure they have systems access to assist you with the ACAT process. Registered Non-Income Producing Assistants These individuals will be required to go through the same application process as you. This will need to be done simultaneously with you to ensure they have systems access to assist you with the ACAT process. Non-Registered Assistants An Electronic Fingerprint Request form must be completed and submitted to the Licensing department. The Licensing department will coordinate with the Assistant to schedule fingerprinting through our vendor, Business Information Group. Once this has been completed, the fingerprints will be submitted electronically to FINRA for approval. Once approval has been received, the Assistant will be assigned systems access. Non-registered assistants can perform ministerial administrative tasks under your direction and supervision, but may never discuss client accounts or investments with clients, handle client funds or securities, or perform any other function that would require a securities license. 9

12 STEP THREE TRANSFERRING YOUR CLIENT ACCOUNTS Currently, your client accounts are being held in one of two ways: in a brokerage account or directly with the product sponsors. Where your client accounts are held determines the procedure you will need to follow. The three general transfer scenarios are: Accounts that are held directly with product sponsors Brokerage account transfers into HD Vest s clearing firm (First Clearing, LLC) Consolidating outside (directly held) fund positions into First Clearing Please note that block transfers are not permitted. ACCOUNTS HELD DIRECTLY WITH PRODUCT SPONSORS Your client accounts may be held in the client s name directly with a mutual fund, insurance company or other product sponsor. If this is the case, you will need to change the broker/dealer of record on these accounts. HD Vest has selling agreements with many mutual fund and insurance companies, and product sponsors will only transfer the broker of record to HD Vest if there is a current selling agreement in place. If you have significant assets with a company and are not sure whether HD Vest has a selling agreement with that company, you should discuss this with your Business Development Consultant. Account Record Change Form and Mutual Fund Application For accounts held directly with the product sponsor, clients will complete the Account Record Change Form (ARC) (see sample in Appendix Three) and the HD Vest Mutual Fund Application (see sample in Appendix Three) to authorize transferring their accounts to HD Vest. Both forms can be accessed via the Forms Gallery on HDVLink. Use one ARC form per household for all accounts at each product sponsor. For example, if you have a family with four Putnam accounts (one joint account, one custodial account and two IRAs), you can reference all of their Putnam account numbers on one ARC form with signatures of all account owners. If the accounts are spread over multiple fund companies, you will need to fill out an ARC for each fund company. The HD Vest Mutual Fund Application is also needed for each registration that the client has. For example, if the client has a joint account and an IRA, then two HD Vest Mutual Fund Applications are needed (no matter how many sponsors are involved). These forms contain important information that the Firm is required to collect and maintain to meet regulatory requirements related to suitability, customer identification and anti-money laundering. Forms Gallery Location: HDVLink > Mutual Funds > Tools > Forms Gallery Please note: As a best practice, include a recent account statement (dated within 90 days) from the product sponsor. When submitting a Trust Account Record Change Form held at directly with a mutual fund, include the first and last page of the trust document. Remote Capture the completed ARC forms along with the HD Vest Mutual Fund Applications, with original client signatures, to the HD Vest Operations department for processing. Once we process these forms they will be forwarded to the product sponsor to have the broker/dealer changed. This paperwork can also be mailed or faxed to the HD Vest home office. Please note: Remote Capture is an online tool that allows you to send forms to us electronically. As a best practice, submitting the required paperwork via Remote Capture allows for automated workflow eliminating potential delays associated with mail or facsimile. Remote Capture Location: HDVLink > Advisor Center > HDVDocs > Remote Capture 10

13 Retain copies of the forms for your records and follow up with the respective sponsors to ensure that your clients accounts have been switched to HD Vest. Most fund families facilitate these transfers in a timely manner. HD Vest offers online reporting of mutual fund accounts (such as Portfolio Reports) via HDVLink. However, please note that in most cases your client accounts will be manually added to these reports by the Operations department after the broker/dealer has been changed at the product sponsor. If you do not immediately see your client accounts on HDVLink, do not be alarmed. We also offer access to the DST Vision or Advisor Central industry websites, and through these tools you will be able to determine which accounts have been changed over to HD Vest and which have not. DST Vision and Advisor Central Location: HDVLink > Mutual Funds > Tools > Access to DST Vision/Advisor Central ANNUITIES The process to transfer variable and fixed annuities to HD Vest is very similar to mutual funds. We require an Account Record Change Form (ARC). Use one ARC form per household for all accounts at each product sponsor. In addition, for variable annuities only, the Insurance Purchase and Exchange Disclosure Form (IPED) (see sample in Appendix Three) is also needed for each registration that the client has. Note that only the clients financial information along with the signed client agreement is needed from the IPED form. Equity Indexed Annuities require the Indexed Annuity Disclosure Form (see sample in Appendix Three) and you will need to ensure that you update your Outside Business Activities under your Advisor Profile on HDVLink. You will need to list your Outside Business name as HD Vest Insurance Agency with the HD Vest home office address, select the appropriate Business Category, and the Position should indicate Equity Indexed Annuity. Advisor Profile Location: HDVLink > Advisor Center > Advisor Profile - Scroll down to Outside Business Activities EIA Approved List Location: HDVLink > Insurance > Services > Fixes and Variable Annuities > Equity Indexed Annuity Policy - EIA Approved Product List is located under Related Topics Please note: As a best practice, review approved Equity Indexed Annuity (EIA) Product List to confirm our approved EIA products. In addition, include a recent statement (dated within 90 days) from the product sponsor. A Word about Variable Annuities and Variable Life Before any variable annuity and variable life accounts can be transferred, your individual appointment with the insurance company must be transferred to HD Vest. This appointment cannot be changed until FINRA has transferred your registration to HD Vest. To expedite this process, contact the Insurance Licensing department to let them know the appointments you would like to transfer. Contact Insurance Licensing at (866) , option 1, x4609. Please note: As a general rule of thumb, life insurance policies sold as a career agent are not transferable. Qualifying is based on length of service; some career agents are vested in their books of business and are allowed an exception to the general rule. BROKERAGE ACCOUNT TRANSFERS TO FIRST CLEARING If your client accounts are currently registered in street name and held in a consolidated brokerage account, you will need to transfer these accounts using our brokerage account transfer systems. This is generally referred to as an Automated Customer Account Transfer (ACAT). You must also complete both the Customer Account Transfer form (see sample in Appendix Three) and the brokerage New Account Application (see sample in Appendix Three), using our VestWizard tool, which is used to open a new brokerage account at HD Vest. VestWizard location: Tool: HDVLink > Vest360 tab > I want to dropdown menu > Open an Account or View VestWizard Dashboard Information: HDVLink > Brokerage > VestWizard 11

14 The ACAT represents a transfer of accounts between member firms. According to industry rules, once the process has been initiated with First Clearing, member firms must process all retail and qualified account requests received in good order within seven business days. The ACAT system, generally considered faster than its non-automated counterparts, is designed to move entire or partial positions held in the account as they appear on your client s statement. Upon receipt of the transfer request, your client s previous clearing firm will cancel all open orders and restrict future trades from occurring during the transfer process. Please note: Many delivering firms will charge an account termination fee. This fee is charged to the client s account before it is delivered out. The fee varies depending on the firm. Moreover, retirement accounts may be charged an IRA closing/annual maintenance fee in addition to the termination fee. Please check with the specific firm for fee information. In addition, if the above fees cause a negative cash balance situation to occur, many brokers will transfer that negative cash balance over to First Clearing in conjunction with the other securities transfers. The debit would then need to be resolved on the First Clearing side by having the client send in additional funds for deposit, or by placing a sell order to create sufficient cash in the account. The ACAT procedure is as follows: Submit a Transfer Request in VestWizard VestWizard Location: HDVLink > Vest360 tab > I want to dropdown menu > Request Transfer into Brokerage Submit one ACAT transfer request per account number. VestWizard will designate required fields to be completed before submitting. VestWizard will generate the required forms to be submitted. Please include a recent account statement from the contra-firm (dated within 90 days) for each client. Please include a Signature Guarantee Form with each transfer submission. (The client does not have to sign this form). This will allow HD Vest to provide a signature guarantee to the contra-firm if we are requested to do so. Additional First Clearing forms may be required in certain circumstances. Contact General Support at (866) , option 2, to cover additional transfer forms required. Examples: Trust accounts require the Trustee Certification of Investment Powers (TCIP) form. All corporate accounts require a Money Services Business Questionnaire as well as the company s Corporate Resolution. In addition to corporations, all partnerships, government organizations and non-profits require due diligence forms. Please contact the HD Vest Compliance team for more details on opening these types of accounts. Accounts trading Options would require the Option Agreement. If check writing is requested, the Advantage Account Agreement is needed. (See more on Advantage Check Writing below.) CONSOLIDATING OUTSIDE FUND POSITIONS TO FIRST CLEARING (FCC) If your client accounts are held directly with a mutual fund sponsor or bank and you want to consolidate these accounts by transferring them to First Clearing, this is called a Non-ACAT transfer. To complete this transfer, use the same First Clearing Customer Account Transfer form. VestWizard tool will generate the required form for the client(s) to sign. VestWizard Location: HDVLink > Vest360 tab > I want to dropdown menu > Request Transfer into Brokerage 12

15 Advantage Check Writing If the client wants to initiate or maintain check writing and/or debit card features on the First Clearing account, an Advantage Account Agreement is necessary. Once the Advantage feature is established, new checks and/or a new debit card will be issued. Please be sure all checks have cleared before submitting the transfer paperwork. All old checks should be destroyed. Advantage Checking includes: Unlimited check writing Optional Advantage debit card with access to more than 12,000 Wells Fargo ATMs nationwide with no service fees. If non-wells Fargo ATMs are used, a surcharge fee may be assessed by the other institution. 24/7 online account access Online access to CheckFree Bill Pay services with no monthly service fee. Enhanced statements and expense tracking Easy-to-read consolidated monthly statements Payee information included on statements Expense tracking options Automated daily cash sweep All cash balances in a client s brokerage account are swept daily into the Bank Deposit Sweep or an eligible money market fund. The sweep occurs daily for new cash deposits in IRA accounts, Advantage accounts and in standard brokerage accounts when cash balances are $1,000 or more; otherwise, if new cash deposits in standard brokerage accounts are less than $1,000, the cash balance will be swept weekly. Annual summary and tax documents If a client has the debit card feature on their account or more than $50,000 in assets at year end, they will receive an annual summary that will include all transactions in the brokerage account with the Annual Summary and Tax Package. Advantage Check Writing Location: HDVLink > Brokerage > Resources > Advantage Mutual Fund Periodic Investments and Systematic Withdrawals If the account has mutual fund periodic investments (PIPs), systematic withdrawals (SWPs), or periodic money movements established, these will stop once the account is transferred and will need to be established in the new account. PIPs and SWPs can be established online in IBW and do not require paperwork to be submitted. Establishment of a periodic money movement will require a form that needs to be signed by the client and submitted to HD Vest for processing. The Asset Movement and IRA Service Request tools are available on HDVLink and will generate the required form. Please note: The position must be transferred or purchased in the account before any systematic liquidations can be established. Service Request Location: HDVLink > Brokerage > Tools > Account Setup & Maintenance > Service Requests > Asset Movement (non-retirement accounts) or IRA Service Request (retirement accounts) TIPS TO GUIDE YOU THROUGH ACAT AND NON-ACAT TRANSFERS Reviewing Client Accounts Before the Transfer Review your client accounts for any transactions that need to be completed within the next four to six weeks. Complete them to the extent possible in order to avoid the effects of any blackout period. Check your client s most recent statement for cash debit balances. Clients should pay off these debits before submitting paperwork. 13

16 When establishing a new brokerage account via VestWizard, it is important to ensure that the account registration, names and tax ID on the account at the carrying firm all match the registration of the new FCC brokerage account you will be establishing. Please note: For assistance with Non-ACAT transfers, contact our General Support department at (866) , option 2. Proprietary/Non-Transferable Products Some positions may not be transferable into a FCC brokerage account. To determine if the proprietary funds or other securities your clients hold are transferable, please contact our General Support department at (866) , option 2. If certain positions cannot be transferred, you should not recommend that they be liquidated based on this fact. A recommendation to a client to liquidate any product must be suitable based on the client s financial needs and objectives, and there must be clear benefit/need for the client to sell the investment and purchase another one. In the event that there is a clear benefit and the client does choose to liquidate the investment(s), a Letter of Acknowledgment Regarding Change in Investment Portfolio (LARCIP) form must be completed, signed by the client and submitted with the new account paperwork. LARCIP Location: HDVLink > Brokerage > Tools > Account Setup & Maintenance > New Account > Forms Gallery - In the keyword search, type in LARCIP Once the client s brokerage account is transferred, any residual monies will be transferred to the new account. Brokerage firm money market positions are automatically liquidated in the ACAT process. Margin Requirements All brokerage firms have different margin requirements. If you are transferring a margin account with obscure positions or high loan-to-value ratios, please call the General Support department at (866) , option 2, so we can verify what First Clearing s margin requirements are for that particular account or security. Account and Mutual Fund Coding When transferring mutual funds to a FCC brokerage account, the dividend coding of the mutual funds can be elected on the account transfer paperwork if it is noted on the account statement. If the reinvestment election is not made on the transfer form, the default will be set to reinvest. When the mutual fund position is received in the First Clearing account, the distribution options can be changed. In Integrated Broker Workstation (IBW), go to the Account Balances and Positions page where you can change the dividend reinvestment option for each mutual fund held in the account. IBW Location: HDVLink > Brokerage > Tools > Brokerage Trading Tools > IBW TIMING YOUR ACCOUNT TRANSFERS When transferring to a new broker/dealer, you may want to take the following into consideration when you are making a decision regarding the timing of your transfer. Trail Commissions from Accounts Held Directly with Product Sponsors For directly held accounts, product sponsors generally pay 100 percent of the trail commission payment to the broker/dealer listed on the account at the time the trail commission is calculated. However, some sponsors will prorate the quarterly trail commission between the two broker/dealers. Most commonly, but not inclusively, product sponsors calculate trail commissions on a calendar quarter basis. For specific calculation dates, please check with the product sponsor. Trail Commissions from Positions Held in Brokerage Accounts Trail commissions on positions held in brokerage accounts are generally paid to the broker/dealers on a prorated basis. For example (assuming the trails are calculated quarterly), if the brokerage account is transferred to HD Vest on March 1, then two-thirds of the first quarter trail commissions are paid to the old broker/dealer and one-third is paid to HD Vest. 14

17 STEP FOUR ESTABLISHING YOUR PRESENCE BRANCH OFFICE IDENTIFICATION When you become an Advisor with HD Vest, you will be designated as a branch office, unless you are joining the existing branch office of another Advisor. A branch office is a location identified, by any means, to the public or customers as a location at which the Advisor conducts securities business. Advisors must be careful not to identify any location, other than the branch office, as a place where securities business is conducted. The HD Vest Licensing department handles your branch registration when you affiliate. You will be registered with FINRA and with your state (depending on certain state requirements). Guidelines FINRA branch offices are required to display the HD Vest Investment Services SM and SIPC signs. These signs will be sent to you upon registration and must be displayed prominently in your office location. Securities files and investment records must be kept separately from files related to other business activities and must contain the required information. Compliance Required Files Location: HDVLink > Compliance & Sales Supervision > HD Vest Branch Exams > Branch Exams Advisors offices are subject to inspection by the SEC, FINRA, state regulators, and HD Vest. RETAIL COMMUNICATIONS WITH THE PUBLIC HD Vest policies state that various investment-related communications with the public must be approved prior to distribution. The review of Advisor s submissions is handled by a dedicated team at the home office, Advertising Compliance. Advertising Compliance utilizes the Customer Service Log (CSL) system to facilitate the review of any material you submit. Submissions received each day prior to 2 PM. Central Time will have a CSL opened the same day. Submissions received after 2 PM. Central Time will have a CSL opened the next business day. Within the CSL tool you can view your open and closed logs or perform a search of your logs by entering a date range. CSL Location: HDVLink > Advisor Center > Tools > Customer Service Log (CSL) All submissions are reviewed in order of receipt. The initial review of your submission will typically occur within five business days. All compliance review comments and the status of your submission will be communicated via CSL. Please monitor your logs closely for any required revisions you must submit for re-review. Items that are required to be re-submitted for review and final approval will typically be reviewed within two business days. 15

18 Business Cards and Letterhead One of your compliance requirements is to have an approved investment related business card and letterhead. You can access information pertaining to the necessary procedures to order business cards and stationery on HDVLink. You should have these in place within six weeks of your effective date. Not only does this bring you into compliance immediately but these templates can be printed on card stock from your own home computer or you can take them to your local printer to have a supply printed. Business Cards and Letterhead Samples Location: HDVLink > Sales & Marketing > Sales & Marketing Ideas > Advertising/PR Samples Please note: Any material change such as an add or drop of any securities licenses, addition of an address, business name, title, website, etc. requires you to submit the new version to Advertising Compliance for review and approval prior to distribution. DISCLOSURES Depending on your licensure, the following disclosure is required to be included on any investment-related item, such as letterhead and business cards: Securities Licensed Only If you only hold securities registration, the following disclosure is required on your investment related item: Securities offered through HD Vest Investment Services SM, Member SIPC 6333 N. State Highway 161, Fourth Floor, Irving, TX (972) If you have your FINRA branch office address on your submission, you have the option of removing the home office address from the above listed disclosure. Securities and Advisory Licensed If you hold both a securities and advisory registration, the following disclosure is required on your investment related item: Securities offered through HD Vest Investment Services SM, Member SIPC Advisory services offered through HD Vest Advisory Services SM 6333 N. State Highway 161, Fourth Floor, Irving, TX (972) If you have your FINRA branch office address on your submission, you have the option of removing the home office address from the above listed disclosure. Outside Company Name Used If you mention an outside business name in your submission, the following disclosure is required: (INSERT COMPANY NAME HERE) is not a registered broker/dealer or independent investment advisory firm. Below are the standards for the font size of the disclosure in your submission. 16

19 Item Business Cards Letterhead Signs Directory Advertisements Other Items Disclosure Font Size Minimum six point disclosure font size Minimum eight point disclosure font size The disclosure font size must be relative to the verbiage font size used on the sign for example, if the text of your sign is 30 point font size then the disclosure should be 25 point not eight point The disclosure font size must be relative to the verbiage font size used in the ad for example, if the text of your ad is 12 point font size then the disclosure should be 10 point not six point The disclosure font size must be relative to the font size used in the main body of the advertisement ADVERTISING COMPLIANCE SUBMISSION PROCESS Materials may be submitted to Advertising Compliance via: Fax (972) Mail Advertising Compliance 6333 N. State Highway 161, Fourth Floor Irving, Texas COMMUNICATION Policy HD Vest policies state that any investment related correspondence should be sent from your hdvest.net address. If you use an outside address, you are required to carbon copy (cc:) your hdvest.net address on all incoming and outgoing correspondence related to your securities business. It is your responsibility to comply with this regulatory requirement, and failure to do so may result in serious regulatory issues and possible termination from HD Vest. Outside Address Requirements Any address you utilize for investment communication must be disclosed, as well as your outside address. Location to Disclose Your Address: HDVLink > Advisor Center > Advisor Profile - Scroll down to section Additionally, you are required to submit your signature for this address for review and approval prior to use. The approval must be maintained in your office in the Advertising Compliance required file and the signature must be reviewed annually per HD Vest policies. HDVest.net Accounts Communications sent from your hdvest.net account have the appropriate HD Vest standard disclosure included. Any additional signature that is more than your individual name and the title HD Vest Advisor is required to be submitted to Advertising Compliance for review and approval prior to use. The approval must be maintained in your office Advertising Compliance required file and the signature must be reviewed annually per HD Vest policies. 17

20 Websites All websites must be disclosed on your Advisor Profile on HDVLink and submitted to Advertising Compliance annually for review. This includes non-investment related websites and websites for outside businesses. You may maintain a discounted web site through our strategic partnerships with industry leaders for Advisor websites, which provide a compliance interface with our teams. Location to Disclose Your Website: HDVLink > Advisor Center > Advisor Profile - scroll down to website section A website is deemed investment-related if it contains any information regarding investment services or products. Websites might include tax information as it relates to investments; however, the inclusion of this information for any purpose by an Advisor requires it to be compliant with current FINRA regulatory rules and firm policies. Please note: If you intend to use a website to advertise the investment services and products you offer through your affiliation with HD Vest, outside of those offered by through strategic partnership vendors, you must complete an outside website agreement, pay all associated fee(s) and make all necessary changes as directed by the Advertising Compliance department. Due to the increased level of supervision and oversight required on advertising with potentially unlimited and non-targeted audiences, such as websites, there is an annual fee for an outside investment related website of $750. This cost does not include the potential FINRA filing cost that may be incurred. The outside website agreement is available upon request from the Advertising Compliance team. Social Networking and Online Advertising Due to the potentially unlimited and non-targeted nature of online audiences, our oversight of the use of these tools requires that you participate in an Attestation & Training requirement and provide these services through our approved provider. Social networking websites such as Facebook, LinkedIn and Twitter are covered in this training. CORRESPONDENCE Overview Q: What is correspondence? A: Correspondence is any written letter or electronic mail message distributed to a single client; this includes letters, s, memos, notes, etc. including incoming correspondence from clients (this is not an all-inclusive list). Q: Do I need to submit correspondence for review prior to use? A: Correspondence does not require pre-approval. Q: How is correspondence different than investment communication? A: Correspondence is any letter or sent to a single client. If you send the same letter or to multiple clients it will be considered investment communication and requires pre-approval prior to distribution. Q: What are the requirements for submitting correspondence to HD Vest home office for review? A: All incoming and outgoing client correspondence must be forwarded to HD Vest for review within seven business days of receipt or of being sent. Q: Do I need to send the hard copy of the I sent to a client? A: No. Electronic investment related messages must be sent from your hdvest.net account or if using a disclosed outside address you must cc your hdvest.net account. 18

21 Q: Where can I send correspondence for review? A: Any written letter can be scanned and ed to corr@hdvest.com or faxed to (972) Correspondence can also be mailed to the home office: HD Vest Advertising Compliance Attn: Correspondence Review 6333 N. State Highway 161, Fourth Floor Irving, Texas Correspondence Communication Standards Q: What are the content standards for client correspondence? A: Traditional standards for communications with the public apply to correspondence. Communications may not contain any untrue, false or misleading statement, any promises of specific results, or exaggerated, flamboyant or unwarranted claims; or, opinions for which there is no reasonable basis, or projections or forecasts of the future. All claims must be able to be substantiated. Any claims that cannot be substantiated are considered misleading and should be removed from any communications. Q: What disclosures should I use on correspondence? A: At a minimum you need to have your broker/dealer disclosure present on all communications. Any written correspondence must be done on approved investment related letterhead. All electronic messages that are not sent from your hdvest.net account must include an approved signature. Q: I have included enclosures with the correspondence, should I send these for review? A: Enclosures are required to be included when submitting correspondence for review. Prospectuses, HD Vest or product sponsor account forms do not need to be forwarded. Q: How do the recent changes to customer reporting rules impact correspondence? A: Custom or consolidated reporting are not permitted by Advisors. Approved reports for use with clients include those found on HDVLink, Morningstar, Black Diamond, or product sponsor/fund family websites. You can give your client their account balance as long as you give the account type, date and source of the information, for example your IRA account balance is XXX as of 04/01/2014 per DST vision. Best Practices Q: How do Advisors ensure they are forwarding correspondence in time for review? A: Advisors with both high and low volumes of client correspondence often will create a weekly task to forward any correspondence not previously forwarded to HD Vest for review. You can keep all correspondence in a single secure location in your office, then once a week make copies/send into the home office and file away in your correspondence file. must be forwarded to your hdvest.net address for archival and review purposes. Q: How do I ensure the content is fair and balanced? A: Please discuss all costs and risks of any investment strategy or product whenever giving a recommendation. To make this easier, we have a list of disclosures available on HDVLink which can be used when talking to your clients about the benefits of certain products/strategies. You must ensure all claims can be substantiated; this can be done by quoting sources on the item in footnotes, for example the market has continued to make progress in the last quarter 1 footnote: 1 Source Bloomberg issue XXX date XXX. Common Disclosures Location: HDVLink > Compliance & Sales Supervision > Advertising Compliance > Common Disclosures 19

22 THE CORRESPONDENCE REVIEW PROCESS Q: What happens if there are issues with my correspondence? A: For most issues Advertising Compliance will open a Customer Service Log (CSL) to communicate what the issue is, and how it can be avoided in the future. No action is required on your part. The log is for your information as guidance for future reference. If further information is required regarding the content of the correspondence, a log will be forwarded to your sales supervisor for review and follow up. Q: Why has my correspondence been referred to another team in Compliance? A: Based on the content of your correspondence and any potential issues related to the activity described within it may require Advertising Compliance to refer your item for follow up by another Compliance team. For example, if your correspondence references a client who is residing in Brazil (a non-permissible foreign country) this item would be referred to our Anti-Money Laundering (AML) Team for further review. CLIENT NOTIFICATION We recommend that you send clients a letter of notification indicating that you have joined HD Vest. A pre-approved letter is available through MarketingPro, Inc., a strategic partner that offers thousands of marketing messages you can send to your clients. Note that this is a subscription-based service with several options available for Advisors. Location: HDVLink > Sales & Marketing > Marketing Tools > MarketingPro, Inc. 20

23 STEP FIVE TECHNOLOGY HD Vest offers a wide array of technology and tools to operate your business effectively and efficiently. Below is an overview of some of these tools. More information and training on these tools are available on HDVLink. VESTWIZARD TM The VestWizard tool will help ensure your brokerage accounts are established quickly and accurately while mitigating Not in Good Order (NIGO) items. With intuitive navigation and real time integration with Vest360, VestWizard prompts you for the client information needed to efficiently and successfully open each new account, minimizes the number of forms clients must sign, and reduces the re-keying of data. This creates a seamless process for completing brokerage account opening. This initial launch of VestWizard will also allow for the creation of transfer requests. Additionally, you will be able to establish accounts 24 hours a day, seven days a week and print account documents before final submission. VestWizard location: HDVLink > Vest360 tab > I want to dropdown menu > Open an Account or View VestWizard Dashboard To facilitate your introduction to VestWizard, a training demo is built directly into the tool or you can view the FAQs on HDVLink > Brokerage > VestWizard. ACCOUNT SETUP AND PROCESSING (ASAP) ASAP is an online application that allows you to establish new directly held mutual fund accounts at fund sponsors. You can also process most fund purchases through ASAP as well as apply for fund features such as checkwriting or systematic investments. ASAP is a rules-based tool that allows you to open new mutual fund accounts and eliminate paperwork errors in the process. Currently ARC forms are not supported via ASAP. However, once the new account information is added, you simply print out the account forms, get client signatures, submit the account and forward to the HD Vest Operations department for processing. ASAP Location: HDVLink > Mutual Funds > Tools > ASAP 21

24 BROKERAGE MAINTENANCE REPORTS A variety of reports are available to you to help maintain your client s brokerage accounts. These reports include accounts: with debit balances, with insufficient funds to process a scheduled distribution, that become restricted, and/or that may be subject to maintenance fees, etc. You will be notified of these items via the Action Items dashboard on HDVLink. Brokerage Report Location: HDVLink > Report Center > Brokerage Reports CUSTOMER SERVICE LOG (CSL) If you need to make HD Vest aware of a service-related item, or simply have a question, you can submit the inquiry via the CSL system. It takes just minutes to open a log, and we have dedicated professionals who are assigned for proper resolution. You are able to view the CSL along with any comments that are placed in the log online. You are also given an approximate time frame as to how long the inquiry will take to resolve. Some departments at HD Vest also use the CSL to proactively notify you of different issues, such as compliance issues, not in good order (NIGO) items, advertising approvals, operational issues, etc. The CSL will notify you by action item or when logs are opened, closed and when comments are made. CSL Location: HDVLink > Advisor Center > Tools > Customer Service Log TRADE MANAGEMENT TOOL (TMT) TMT is a robust trading and management tool available to assist you in managing your clients investments. The tool allows you to group accounts, establish models with assigned portfolio weightings, and systematically rebalance your clients accounts according to the assigned models. TMT Location: HDVLink > Advisory Services > Tools > Advisory Trading Tools > Trade Management Tool INTEGRATED BROKER WORKSTATION (IBW) IBW is an online account servicing and trading tool that will assist you in servicing your clients brokerage accounts. This tool, if you are appropriately licensed, allows you to place mutual fund, equity and option trades, and also gives you access to information pertaining to each brokerage account such as registration, account features, balance/positions, account history and account suitability. IBW Location: HDVLink > Brokerage > Tools > Brokerage Trading Tools > IBW

25 VEST360 TM Vest360 gives you access to complete client account level data and a 360-degree view within a dashboard of all client assets. You will have access to three different pages or views: across your entire client base, for a particular client and by account. The platform delivers a user-friendly interface built with the latest website design standards. It s accessible via mobile devices and tablets, as well as across multiple browsers. Vest360 provides you with quick access to the most important information and actions you need to take from one central location. Since Vest360 is your centralized hub of information, this is where you will access tools such as VestWizard, the 1040 Analyst TM and VestVision TM. Client Center Location: HDVLink > Vest360 tab VESTVIEW TM VestView is the one-stop shop for Advisor Business, which houses all important information about you and your business. You can expect to find: A drop-down menu that will help you perform the most common Advisor tasks. A way to view commission statements more clearly by month and year. You can also search for specifics within your statement, export and save it. A dashboard that will provide easy access to information about your 1099s, licenses, annual business requirements, rolling gross, reports, rankings, and more! VESTVISION TM VestVision is a comprehensive eight-step planning process that was designed from your clients point of view and allows them to be involved in every step of their investment plan. This investment and retirement planning system provides you with the tools and technology you need to help your clients identify and prioritize their life goals, decide on an appropriate investment strategy, monitor their progress, and make revisions whenever necessary. Through VestVision you can help your clients bring their future into focus. HDVDOCS Through HDVDocs, you will be able to scan, search, view, and obtain the status of your submitted client account paperwork through Advisor Center and Vest360 on HDVLink. Once account documents arrive in the HD Vest mail room, either from Remote Capture in HDVDocs or via overnight mail, the paperwork is sorted manually or electronically, scanned (if applicable) and electronically routed to the appropriate processing area. As soon as we have launched your client s paperwork to the workflow system, you can see the paperwork s real-time status through Document Search or Vest360 on HDVLink. HDVDocs Location: HDVLink > Advisor Center > HDVDocs > Document Search or Remote Capture REPORT CENTER Using Report Center, HD Vest presents the available reports by most commonly accessed groupings including Client, Advisory, Brokerage, and Consolidated. The Client report categories include Analytical, Portfolio Summary, Performance, and Advisory Account Detail. The Advisory report categories include VestAdvisor/Select, WFA and Archived. The Brokerage report categories include Balances, Activity, Action Items, and Account Search & Review. The Consolidated report categories include Positions, Transactions and Archives. Report Center Location: HDVLink > Report Center 23

26 APPENDIX ONE TRANSITION TIMELINE TIMELINE STEP ONE STEP TWO STEP THREE STEP FOUR FOUR WEEKS BEFORE TRANSFER Complete your transfer application and submit it to your Business Development Consultant. Organize and review client files in preparation to complete HD Vest new account forms, upon successful registration. Verify if your current broker/dealer will be charging transfer fees on clients accounts. Check accounts for available cash to cover fees before transferring. ONE WEEK BEFORE TRANSFER WELCOME ABOARD AS A NEW HD VEST ADVISOR Compose your letter of resignation. Once your licenses have transferred to HD Vest, you ll receive a call from your Business Development Consultant. As clients receive your mailing, they will be calling your office. Prepare and train your staff to handle your clients immediate questions and concerns. Contact your Business Development Consultant to discuss how you would like to proceed with your transfer on resignation day. Licensing will assign you a representative number and a branch number. Use HDVLink to keep track of account transfer paperwork sent to and received from your clients. Submit a copy of your resignation letter to your Business Development Consultant. Start calling clients to let them know you about your new affiliation, send out client mailing and instruct your clients to mail all forms back to you as soon as possible. Familiarize yourself with HD Vest s Compliance Manual. Once you have completely read the Compliance Manual, please sign the acknowledgement form and return it to Compliance. Provide a name and telephone number of a person at your current broker/dealer so we can confirm your resignation. Look for an from your Wealth Management Consultant with your personalized password to HDVLink. Prepare new client files, set up branch office compliance files and send out your approved thankyou letter to clients who have returned their transfer forms. Prepare a friendly follow-up letter to send to clients who are slow mailing back transfer forms and submit the letter to Advertising Compliance for approval. 24

27 APPENDIX TWO FREQUENTLY ASKED QUESTIONS In order to make this transition as seamless as possible, we ve compiled a list of our frequently asked questions regarding the transfer process. These questions highlight the main topics in this guide and more. Q: When should I submit all my licensing materials to HD Vest? A: You should send everything in at least four weeks prior to the day you wish to transfer. This enables us to review the application for approval and check to see that everything is complete and in good order. Q: Will you notify my current broker/dealer prior to my resignation? A: No, we only contact your broker/dealer after we receive a copy of your resignation letter, to confirm your resignation has been processed. Q: How long does it take to transfer my licenses to HD Vest once I resign from my current broker/dealer? A: Generally, your securities license can transfer via the TAT system in 48 to 72 hours. However, some states may take longer if they do not participate in the FINRA TAT process. Also, if you have any disclosures, the process can take considerably longer. Q: Does HD Vest offer Errors and Omissions (E&O) insurance? A: HD Vest has arranged for a competitive and affordable E&O program for its Advisors. The policy is brokered by Aon Risk Services and is underwritten by Continental Casualty Company, a highly rated insurance company that is very familiar with the broker/dealer business. Optional coverage is also available to cover tax and accounting services. Contact the Plan Administrator at the number below for quotes or further details. Affinity Insurance Services, Inc. 159 E. County Line Road Hatboro, PA Phone: (866) info@agents-eo.com Q: How often do you pay commissions? A: Commissions are processed twice per month, on the 15th and last business day of the month. Payments are made approximately five business days after the 15th and the last day of the month. There is a commission schedule available on HDVLink showing the exact dates. Commission Schedule Location: HDVLink > VestView tab > Commission Statements Direct deposit instructions should be provided with your initial paperwork package so that commissions can be sent by ACH. If ACH is not established, a $10 fee is assessed for manual checks. Direct Deposit Location: HDVLink > Mutual Funds > Tools > Forms Gallery - In keyword search field, type in direct deposit, and select Authorization Agreement for Direct Deposit form. 25

28 Q: Will I be viewed as a branch office? A: Unless you are joining the same office as another HD Vest Advisor, you will be established as your own branch office. Q: What is fidelity bonding? A: HD Vest is required by FINRA to maintain a surety bond. The total cost of the bond is shared equally among all Advisors and included in the annual affiliation fee. The surety bond covers employees of HD Vest and protects your clients against losses which may arise on the premises of the broker/dealer, in transit to the broker/dealer, from misplacement, as a result of forgery and alteration, and/or as a result of fraudulent trading. Q: How often do I pay licensing fees? A: Whenever you request a new state registration or need to take a FINRA exam, you will be charged the appropriate fee. Annual renewal fees are automatically charged to your September commission statement for the following calendar year. If you wish to pay the fees by check or credit card, then your statement is credited for that amount. The Licensing department makes certain that all Representatives registrations are renewed annually. Q: To whom do I speak to get licensed with insurance and variable annuity companies that I currently do business with, or that I wish to do business with? A: You will need to contact our Insurance Licensing department at (866) , option 1, x4609. Q: Can I use a DBA name? A: The use of doing business as (DBA) names in conjunction with HD Vest is permissible, subject to including appropriate disclosures; however, if you do choose to use a business name, please be sure that it does not create the impression that you are a broker/dealer or an investment adviser. All outside business activities and letterhead or business cards using a DBA must be disclosed on the Other Business Disclosure Reporting Page and submitted to the Compliance department for review prior to use. Other Business Disclosure Reporting Page is included in your application to affiliate with HD Vest. Other Business Disclosure Update Location: HDVLink > Advisor Center > Advisor Profile - Scroll down to Outside Business Activities & Outside Brokerage Accounts Q: Do you have any material I can use to send to my clients to let them know I m now with HD Vest? A: Yes! We provide pre-approved client letters (see sample in Appendix Three) within HDVLink specifically for this use. Once you have joined our firm, we can introduce you to our approved strategic marketing partner options for additional ease-ofmarketing. Q: When can I send out a letter to my clients to notify them of my new affiliation and have them sign transfer forms? A: Once you have resigned from your former broker/dealer and your license with HD Vest has been approved by FINRA, we recommend that you send clients a letter of notification indicating that you have joined HD Vest. The notification letter should accompany any formal paperwork to be signed by the client. Prior to distribution, please send us the actual letter you plan to use so you can obtain Advertising Compliance approval, unless you are using a pre-approved letter through MarketingPro, Inc. Any contact with clients must be undertaken in compliance with applicable regulations and legal requirements. 26

29 Q: What is the standard account transfer turnaround time? A: For ACAT transfers, the standard transfer time is 10 business days. For Non-ACAT transfers, the standard transfer time is four to six weeks. These timeframes are industry standards. Please note that block transfers are not permitted. Q: If my client is holding proprietary products in another brokerage account, can these be transferred to First Clearing? A: No. Proprietary mutual funds of a brokerage firm are not transferable. If your client s intentions are to liquidate these nontransferable positions, it may be best to have your client liquidate prior to the submission of the transfer paperwork. Your client can also request to liquidate through their Customer Account Transfer form. Please note: Many firms will not accept written liquidation requests and instead require verbal authorization from the client. Q: Can Fidelity Funds be transferred into First Clearing accounts? A: Yes, simply fill out the Customer Account Transfer form. Q: What happens when an account is transferred over to First Clearing through the ACAT system and a dividend is paid to the old account? A: Through the ACAT process, the delivering firm will do a residual sweep of its accounts on a weekly, semi-monthly, or monthly cycle. The residual sweep cycle varies with each delivering firm. Any cash balances will be transferred over at this time. Q: Can I complete forms online? A: Yes. Most forms can be completed online using the Adobe Acrobat Reader (free download available on HDVLink). Simply click on the form, fill it in, print it and present it to your clients for their signature. All forms are available on HDVLink in the Forms Gallery. Forms can be easily located by searching by form name or by clicking on the appropriate HD Vest category. Forms Gallery Location: HDVLink > Mutual Funds > Tools > Forms Gallery Q: How do I order additional supplies, forms and brochures? A: All forms can be printed from the Forms Gallery on HDVLink. Brochures can be ordered using the Online Catalog on HDVLink. Brochure Location: HDVLink > Sales & Marketing > Marketing Tools > Marketing Materials - Online Catalog PDF Previews and Launch Online Catalog are located under Related Topics Q: How do I get a password to HDVLink? A: Once you are licensed, you will receive a user name and password for HDVLink from your assigned Wealth Management Consultant. 27

30 APPENDIX THREE SAMPLE FORMS AND LETTERS Client Notification Letter...30 Customer Account Transfer Form...31 To transfer a brokerage account into First Clearing, LLC HD Vest Account Record Change Letter of Instruction To change name of broker/dealer for accounts held with mutual fund sponsors only Brokerage Account Application...37 To establish a brokerage account into First Clearing, LLC, Customer Service Agreement included HD Vest Mutual Fund Account Application...42 To establish accounts held with mutual fund sponsors only HD Vest Indexed Annuity Disclosure Form This form is required for all initial purchases of indexed annuities, account record changes, and some subsequent investments into an already existing indexed annuity. This document is required per indexed annuity contract established. If a client is setting up multiple annuity contracts for a client, a separate form is required per contract. HD Vest Insurance Purchasing/Exchange Disclosure (IPED) for Variable Annuities This form is required per variable annuity contract established; if a client has multiple group insurance contracts for a client, a separate IPED for Variable Annuities is required per contract. 28

31 Most forms can be accessed on HDVLink through Forms Gallery. The process to print the form or pre-fill the form online is a 4 step process as outlined below: 1. Search for the form in the Keywords field 2. Check the box next to client info unknown and click zoom. 3. Click print or save to desktop (for online form filling) 4. Complete the form Keep in mind that the Brokerage Account Application and the Customer Account Transfer Form can be processed directly through VestWizard. Forms Gallery Location: HDVLink > Brokerage > Tools > Account Setup & Maintenance > Forms Gallery or HDVLink > Mutual Funds > Tools > Forms Gallery Please note: The sample forms provided in this appendix may appear different than they would when you fill out the form online via Forms Gallery. 29

32 SAMPLE Access via MarketingPro, Inc. October 24, 2012 Joann Advisor, Inc. 123 Business Address Irving, TX Phone: (972) Fax: (972) Mr. John Client 500 Client Street Suite 400 Houston, TX Dear John: As your financial professional, I have always been interested in helping you minimize your tax bill and maximize the amount you keep. Therefore, to ensure I can provide you with a broader range of tax and financial services, I am extremely pleased to announce that I have affiliated with a new broker/dealer HD Vest Investment Services SM. HD Vest has been serving the needs of individual investors and small businesses since 1983 exclusively through independent financial professionals such as myself. I am now able to offer my clients a vast array of financial services using a total investment plan that considers a more comprehensive approach. These services include: college planning, retirement planning, brokered CDs* and tax-savings ideas. You have already placed a great deal of confidence in me by allowing me to become familiar with your financial situation, either by preparing your tax return or helping you pursue your financial goals. I greatly value your trust in me. I look forward to further strengthening our relationship with the enhanced client services afforded to us by my new alliance with HD Vest. If you have any questions please feel free to call me any time at (972) Sincerely, Joann Advisor Joann Advisor *CDs are FDIC insured up to $250,000 and offer a fixed rate of return. They do not necessarily protect against a rising cost of living. The FDIC insurance on CDs applies in cases of insolvency of the bank, but does not protect market value. Other investments are not insured and their principal and yield may fluctuate with the market conditions. A Insurance License No «RFname» «RLname», Registered Representative Securities offered through H.D. Vest Investment Services SM Member SIPC 6333 North State Highway 161 Fourth Floor Irving, Texas (972)

33 Customer Account Transfer (Please Use a Separate Form for Each Transfer) FCC Account You are Transferring TO Social Security or Tax ID Number Secondary Social Security FCC Clearing Number Brokerage Account Number Sub Firm # Rep Code or Tax ID Number 0141 Full Name or Account Title SAMPLE Access via HDVLink, Process Online Account You are Transferring FROM Delivery Organizations: See Delivery Instructions on Page 2. Account Name Account Number Name of Firm or Fund Company Currently Holding Your Account Clearing Number Address of Firm Check here if this Account is a: QRP IRA OTA (different account registration) DRT (direct rollover transfer) Type of Transfer 1 Full Brokerage Account Transfer. (Check one at right) Transfer all assets or shares in my account as is Liquidate and transfer cash 2 Partial or Non-Brokerage Transfer. A Trust Company, Bank, Credit Union, Savings & Loan, Annuities, Life Insurance, DRIP Plan Shares or Certificates of Deposit Liquidate all assets and transfer as cash. Transfer all assets or shares in my account as is. Liquidate Certificates of Deposit IMMEDIATELY. (I acknowledge the penalty I may incur from an early withdrawal.) Liquidate Certificates of Deposit AT MATURITY. (Submit this transfer no earlier than 30 days prior to maturity.) Maturity Date B Partial Brokerage, Trust Company or Annuity Transfer. (Transfer only the assets or shares listed below) (Choose one for each Item) Quantity Description of Asset and Cusip or Symbol Liquidate and Transfer cash Transfer Shares As Is *For additional assets please attach a separate sheet 3 Mutual Fund Company Transfer. (One form per Fund Family). Quantity Symbol/ CUSIP Shares or Dollars Name of Mutual Fund Liquidate & Transfer Cash Transfer Shares As Is Fund Account Number (Choose one for each Item) Dividend STG LTG S D C R C R C R S D C R C R C R S D C R C R C R S D C R C R C R S D C R C R C R S D C R C R C R *For additional assets please attach a separate sheet (Rev 07-11/14) Page 1 of 5 31