ADVERTISING AND SALES LITERATURE REVIEW

Transcription

1 ADVERTISING AND SALES LITERATURE REVIEW Summit Brokerage Services User Guide March 2016

2 Advertising and Sales Literature Review To conform with the requirements of FINRA Rule 2210, all communications with the public, including advertising and sales literature, must be submitted to Compliance for review and approval prior to use. In an effort to maintain efficiency with the review of these materials for public use, you must utilize the Advertising Approval Form when submitting to Compliance for review. Depending on the type of advertisement submitted, one can expect a response in 2 business days for most basic pieces (such as stationary, form letters, brochures, etc.) and up to 10 business days for more complex pieces (such as presentations, seminars, websites, etc.). WORK ITEMS CONTENT INDEXING - AN UNINDEXED DOCUMENT As reviewed in the scanning section, a document scanned in without any barcodes will be captured as an unindexed document. An unindexed document resides in the Mailroom. 1. Make sure the work item is in your queue (it may already be there or you need to Get Task from Pool). Select the Contents link to open the work item envelope. 2. The contents of the work item will appear. In this example below, it is a single Unindexed Document. 3. The Unindexed Documents have some indexing characteristics that are auto-indexed on document capture: Rev 3/16 Page 1 of 12

3 a. Creation Date/Time when document was scanned (date and time stamp). b. # of Pages of each document. c. Document ID assigned to each document (serialized as they are captured). d. Batch ID that the document is associated with. e. User who scanned and uploaded the document. f. Confidential: Shows whether document was captured as a confidential document for the user 4. Select the Edit link to the right of the PDF icon in order to start the process of indexing the record. Both the indexing information (left side) and the document image (right side) are displayed 5. You are now ready to index the document. It is Unindexed because we currently have no indexing information Date, Client Document Type, Form and/or Description etc. It is the user s job now to classify the record in order to transition it from Un-indexed to Indexed. 6. Now you will begin to index the document by selecting the correct values in the fields in the template. At the top of the page change from Client Documents to Ad Review Documents. Rev 3/16 Page 2 of 12

4 Helpful hints for completing this page are as seen below: Rev 3/16 Page 3 of 12

5 Client Prospect Mailer/Brochure: Any Mailers sent to clients or prospects, any brochures that will be distributed to clients or prospects (this could include brochures for the services offered, bios for reps, brochures from third party vendors, tri-fold brochures, etc.) Correspondence: Letters to or from clients/prospects Other: anything not fitting into the listed categories Quarterly Certification: Quarterly Certifications or Investment Recommendation blotter for the quarter Radio/TV: ads & segments for TV & Radio, scripts for the TV/radio appearance, post review of the live segments Seminar: Seminar invitations, brochures, mailers, etc. Signs/Billboards: Advertising Signs & Billboards, signs for offices, signs for sponsored events Speaking Engagement: Guest Speaker or Lecturer at an event (non-seminar) Stationary: Letterhead/Envelope, business cards, notepads, etc. 7. Once complete, select Submit. The file has now been moved from the Unindexed Documents section to the Ad Review Documents section. 8. Now you will need to attach the Associated Person Folder to the work item. Select the Edit link under the Actions bar of the Work Item. Step 1 Select the Request Type - Advertising. Step 2 Select Add next to Folder to attach the Associated Person Folder. Rev 3/16 Page 4 of 12

6 9. You will be redirected to the search screen. At the top of the page, select Associated Person Folder (as shown in the box labeled 1). You will then change the Predefined Searches drop down to Search by Rep (as shown in the box labeled 2). The corresponding information displays as shown below. In this case, the rep information populates below. Click the radio button to the left to display the appropriate information for the Work Item. 10. Review the screen to confirm the advisor number and the correct Request Type were selected. If they are both correct, click Submit. Rev 3/16 Page 5 of 12

7 The selected folder will then be assigned back to the Work Item. Upon final submission, the documents within the Work Item will now be filed to the referenced folder. 11. Now that the Work Item and the documents have been indexed, the last action is to determine how to close out the work item. Over in the task bar, the user has fixed selections on how to process the work item: REMEMBER: Archive This archives the work item. You will archive documents that do NOT need to be sent to the back office Trash If for any reason the work item and corresponding documents are not required, you can trash the work item and it will no longer be available in the system Merge Ignore Indexed Ignore Send for Review By selecting Send for Review this item will be sent for the Advisor to Review before sending the document to the back office to process. Close If you need to process the work item at a later date you can simply close it and it will be placed back in your queue. Rev 3/16 Page 6 of 12

8 12. Select the task you wish to associate to this work item. Provided the information is added correctly, the work item will now move on to the next step. If the provided information is incorrect, an error will appear prompting you to change/add additional information and then proceed. Before a Work Item will be sent to Summit Brokerage, the advisor will have to Get Task from Pool on the Ad Review Advisor Review task. The work item must be reviewed by the Advisor before it can be submitted to Summit Brokerage. Shown below is the Ad Review Advisor Review folder. Here the advisor has a chance to approve and make any final changes before submitting to Summit Brokerage. Select the Contents link to open the work item envelope 13. As you click on the Ad Review Advisor Review folder, below you can see Work Items that need attention. Rev 3/16 Page 7 of 12

9 When you click on contents, the Work Item will open allowing the Advisor to make any changes necessary. Once reviewed, if all information is correct, click Send to Back Office. **Side Note: When submitting Quarterly Certifications, refer to the below example. How to Search and Retrieve AdReview/Approvals Document retrieval is one of the core functionalities of any document management system. Docupace provides an intuitive retrieval and navigational desktop based on a user's role, searching scenario, and context. Document management through document retrieval and document distribution is nearly instantaneous through several search methods: Keyword search Cross-reference search between documents with different level index fields Rev 3/16 Page 8 of 12

10 Once a file is retrieved, it can be opened in a viewer window that allows the viewing of documents, adding annotations and highlights, and creating redactions. You can also view multiple versions of a file when needed. In this section you will learn about: Retrieval Page Features Content Folder Structure How to Search for Content How to Use Content Viewers RETRIEVAL PAGE FEATURES After you login, you will first land on the My Desktop page. For access to your AdReview records, select the Retrieve and then select the Associated Person Folder link. (Shown below) This is where you will search/retrieve your AdReview/Approvals. ASSOCIATED PERSON FOLDER Use for storing your documents related to your licensed employees. For example, licensing, continuing education, U4, etc. This is a BD cabinet only. How to Search AdReview Documents (i.e. Sunset Date) Rev 3/16 Page 9 of 12

11 All existing and future compliance-approved sales literature and advertising materials are subject to a two (2) year sunset provision, based on the official compliance approval date. Sunset dates are very similar to compliance approval expiration dates. For instance, if a Representative would like to use a presentation originally approved by Summit's Compliance Department on August 31, 2012, for an upcoming event on October 17, 2014, the material would need to be resubmitted to the Compliance Department prior to use. It is the responsibility of the Representative to determine the approval expiration date. Main items that would fall under the sunset rule are stationary items (business card, letterhead, fax coversheet), brochures, prospect letters, etc. These items need to be resubmitted every 2 years in the event that rules/policies have been updated or changed and revisions need to be made to continue use. RETRIEVAL PAGE FEATURES After you login, you will first land on the My Desktop page. For access to your AdReview records, select the Retrieve and then select the Ad Review Documents link. (Shown below) This is where you will search/retrieve your AdReview documents by Sunset Date. You will need to select the From Date by clicking on the calendar and looking for the beginning date range for the Documents due for Sunset Renewal. Then you will select the To Date in the same way for the ending date range for the Documents due for Sunset Renewal. This feature allows you to select a date and run a report looking for the Documents you will need to resubmit for that month, week, etc. Once you have completed your date range, click on the Submit button and it will bring you to a page showing the list of Advertising Documents that will need to be resubmitted for the Sunset Date searched criteria. Rev 3/16 Page 10 of 12

12 ADREVIEW REFERENCE PAGE Incoming Correspondence Periodic Review: In the home office and OSJ branch offices, the Designated Supervisory Principal or OSJ branch manager shall review randomly, incoming written correspondence for the purpose of identifying any customer complaints; inquiries or instructions from customers; problem situations involving customer accounts; and to ensure that customer funds and securities are handled in accordance with Company procedures as well as other issues of material importance. All correspondence received by associated persons will be subject to review and retention by the Company. In conjunction with the Chief Information Officer, the Chief Compliance Officer will coordinate any appropriate changes in the Firm s procedures. The Firm s system utilizes a list of key word filters to check for inappropriate or noncompliant electronic correspondence. The Company also reviews a random sample of s that passed the filters. Complaints: All complaints received, whether in hard copy or electronic format, must be reported to FINRA in compliance with Rule 4530(d), and should otherwise be handled in accordance with the procedures described in the Customer Complaints section of this Manual. Outgoing Correspondence The Compliance Department must receive and approve a sample of the template used for all computer generated or typed reports (profit/loss, consolidated holdings, etc.) for a customer's account. The Compliance Department will supply disclosure language to be included on the sample template and on each report actually generated thereafter. The disclaimer will be tailored based on factors including the type of report(s) and whether a DBA name is involved and may include that each report is for informational purposes only, that taxes should be prepared from information furnished on 1099's, confirmations, and statements, and an additional disclosure distinguishing securities and advisory services for any representatives using a DBA name. All profit/loss statements must include the commission in the net figures, if applicable. Once the sample template has been approved by the Compliance Department, the report may be customized to reflect each customer s specific account information and forwarded to the customer. A copy of each report distributed to a client must be retained in the client folder. These are subject to review during the periodic office examination or at such other times as may be set by the Compliance Department. Correspondence need not be approved by a registered principal prior to use, unless such correspondence is distributed or made available to 26 or more retail investors within any 30 day calendar-day period and makes any financial or investment recommendation or otherwise promotes a product or service of the member. The Designated Supervisory Principal shall review and approve all outgoing, non-electronic correspondence prior to, or subsequent to, sending. correspondence sent by associated persons will be subject to review and retention by the Company. In conjunction with the Chief Information Officer, the Chief Compliance Officer will Rev 3/16 Page 11 of 12

13 coordinate any appropriate changes in the Firm s procedures. The Firm s system utilizes a list of key word filters to check for inappropriate or non-compliant electronic correspondence. The Company also reviews a random sample of s that passed the filters. It is the Firm s policy that ALL associated persons have their respective address domains hosted solely at Global Relay Communications Inc. or Redtail Technologies. Any exception must be approved by the CCO and CIO. For any exceptions, the Firm must ensure that s to and from these addresses are being journaled to, and archived by, Global Relay Communications Inc., with ability to review all of these s provided to the Company. Facsimile Machines: All facsimile machines used by the Company or its representatives must be: 1. Placed in such a location as to permit monitoring of its use by the Designated Supervisory Principal; 2. Programmed to record the date/time stamp of all transmissions; and, 3. Designed to be accessible only by authorized personnel. For shared-use fax machines, no violation of this policy will be deemed to have occurred if non-business-related faxes are received and sent by the registered representative and his family in the course of conducting their personal affairs. Rev 3/16 Page 12 of 12