Summary
National Financial Services will be charging Premiere Select Retirement accounts the annual $40.00 retirement maintenance fee on November 20th, 2023.

How can I avoid the $25.00 Service Fee for home office covering the fee?
Representatives may review their population of impacted accounts with insufficient funds to cover the maintenance fee by running a report through Wealthscape, beginning September 18, 2023. (Menuà Reports à Client and Account Informationà Retirement Account Annual Fees w. Core Cash Balance).

To assist, ESI Operations will automatically deliver this report to all eligible Wealthscape users through the automated reporting alerts system. The automated report will be delivered during the 4^th Quarter of 2023, on/around the first of each month.

Proactively running the report will allow you 3 months to contact clients and get a trade placed or cover with one of the methods detailed below. It is more efficient to raise multiple years of cash with a single trade, alleviating the need to repeat the process each year and saving on trading costs.

If home office must place a trade to raise cash for the fee, the representative of record will be charged the $25.00 service fee, per trade. Uncollected fees of less than $25 will be reversed against the registered representative’s compensation.

How Customers Can Cover the Fee
Customers have the following payment methods to cover the IRA annual maintenance fee:

• Deduction from qualified account money-market position (default)
• Deposit a $40.00 check using the Wealthscape Investor Mobile App and code as Retirement Maintenance Fee (only available through mobile deposit)
• Journal from their nonretirement brokerage account
• 1st party Electronic Funds Transfer (EFT) from their bank account
• 1st party Intra-Bank Payment (IBP) from their bank account, available to NFS approved, bank affiliated firms

To elect one of these payment methods on an ongoing basis, the Premiere Select IRA Annual Maintenance Fee Payment Instructions Form must be completed. Clients can also elect payment methods on the Premiere Select IRA Application when establishing a new account.

Clients no longer receive a Retirement Fee Invoice, but the following message will be applied to September account statements for impacted account holders:

The 2023 retirement account annual maintenance fee is due on 10/31/2023. This fee covers the costs associated with the recordkeeping of your account and reporting required by the IRS. If you would like to pay the fee from your bank account or your nonretirement brokerage account, contact your broker/dealer. If you do not provide payment instructions, the fee will be deducted from your retirement account on 11/20/23. If funds are not available to cover the fee, your account may receive an unpaid fee posting. Your broker/dealer may sell any or all of your retirement assets to satisfy the fee and any associated expenses such as brokerage commissions and/or liquidation charges. For information about the annual fee, refer to the Retirement Account Customer Agreement or contact your broker/dealer.

Ineligible Accounts and Automatic Waivers
Accounts that are not billing eligible:

• New accounts opened between September 18, 2023, and December 31, 2023, are excluded from the 2023 billing cycle
• Accounts with current year TOA or Full Distribution status
• Closed accounts with less than $35 in market value as of September 17, 2023
• Abandoned accounts (with H1 or H5 restrictions)
• MAD Funding accounts

Accounts with Automatic Waivers

• IRA accounts for the benefit of employees of ESI, National Life and affiliates, including registered representatives, branch office employees and spouses of said employees that are coded as employee accounts
• IRA accounts with total assets of $250,000 or more
• ESI Illuminations accounts that meet program minimums on Valuation Day (September 17th, 2023)

Accounts that are ineligible or qualify for a waiver will not receive the annual retirement maintenance fee notice on their September account statement, nor will they be included in the November fee collection process. A representative can request a waiver of the annual maintenance fee and have it charged against compensation by submitting the Annual Maintenance Fee Waiver Request Form by November 15^th.

Summary of Important Dates

September 15, 2023 – Valuation Day – Account market values and core account balances are recorded in preparation for billing and application of subsidy programs.

September 30, 2023 – Customer Notification – Accounts meeting the billing criteria will receive the annual retirement maintenance fee notice on the September account statement.

November 1^st – 18^h, 2023 – Collection Period – Accounts that have instructions on file to pay the annual maintenance fee via journal, EFT or IBP may have the fee deducted.

November 15, 2023 – Maintenance Fee Waiver Request Deadline – Representatives must submit the Maintenance Fee Waiver Request Form by November 15^th to absorb fees for their clients.

November 20, 2023 – Collection Day – Unpaid fees are posted to customer accounts. Accounts with insufficient cash will result in a cash debit balance.

January 5^th, 2023, through January 27^th, 2023 – Liquidation/Write Offs – Accounts with eligible securities will be liquidated to cover uncollected fees or written off and charged to the advisor on record (if less than $25).

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Here are a few reminders regarding upcoming advisory fee payments from Illuminations and our Direct Money Managers:

• Quarterly Advisory fees are typically billed to the client’s account the first week after each quarter ends/begins
• The ESI Compensation team starts receiving these fees from the vendors about two weeks into the new quarter
• Depending on the day of the week advisory fees are received and processed in good order, they are paid out the following week
• ESI’s commission pay-cycles close each Wednesday and pay the following Tuesday (bank holidays may affect cycle close/pay dates)
• Be sure to check your ACE Commissions portal for incoming advisory fees on your MyView Daily Sales Blotter report

If you need assistance, you can email the compensation team at esicommissions@nationallife.com or call (800)-344-7437, option 2, option 7

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Below is important information regarding the 2024 Annual Renewal process. With the end of the year fast approaching, it is time to start thinking about annual renewals. Important dates and changes are all outlined below.

Renewal Timeline
Key dates for the 2023 renewal period are as follows:

• October 9: Renewal packets will be emailed to the registered representatives directly from ESI Licensing the week of October 9^th.   Registered representatives should promptly complete their packet and return it to ESI Licensing by the deadline. (More information on this is given below).
  
• November 15: Renewal Deadline
  All renewal packets must be received at ESI by November 15, 2023.  RRs who do not return a complete renewal packet and payment by the deadline may not be renewed.
  
• November 30: Termination Notices sent to RRs
  The Firm will send 30-day termination notices to RRs who did not renew by the November 15^th deadline.  Termination from ESI will be effective December 31, 2023.
  
• December 15: Deadline for Termination Requests
  CRD shuts down for 2023 on December 26, 2023 at 6pm (EST) for year-end reconciliation.  Termination requests must be received no later than December 15, 2023 to allow for processing prior to CRD’s shut down.  Any requests received after CRD shuts down will not take effect until after January 2, 2024, and any renewal fees paid will not be refunded.
  
• December 31: Effective date for terminations
  
• January 17, 2024: Final Renewal Invoices emailed to Office Managers

Important Notes for 2024 Renewals
Important points to keep in mind for the 2024 renewal period are as follows:

• Packets will follow the same format as previous years’. Packets will include the invoice, payment options, and options for partial or full termination. All registered persons must complete the annual Registered Representative Questionnaire through Star Compliance.
  
• Reps should create an account or log in to existing FinPro accounts to ensure accuracy of the information to which they attest on Star Compliance.
  
• RRs that become registered with ESI between October 1, 2023 and year-end will be required to pay the applicable renewal fees for 2024, in addition to their registration fees, at the time of registration.  ESI Licensing is available to assist the Office Manager to determine the total amount due for these scenarios. 
  
• Mode of payment must be included with the RR’s renewal. Failure to pay fees by the renewal deadline (November 15th) may result in the RR’s termination for failure to renew.
  
• If an RR is paying via check, they can scan and email their packet back WITH a copy of the check, to ESI Licensing directly at ESI_Licensing@nationallife.com. They do not need to send the original packet, but MUST send the original check to ESI Licensing at the home office. (Checks should clearly indicate the name of the rep to apply payment to).
  
• RRs that request to have their renewal fees deducted from their commissions must have sufficient commissions available.  Pending business will not be considered as part of a RR’s commissions. After selecting that payment option they can scan and email their packet back to ESI Licensing directly at ESI_Licensing@nationallife.com. They do not need to mail the original. If the RR does not have sufficient commissions available, a check must be included with their renewal packet to cover their fees.
  
• If an RR is paying online with credit card, RR MUST include a copy of their receipt/confirmation page with their renewal packet for proof of payment.  Payments can be made in the Agent Payment Center on the NL website.  Chose “Equity Services, Inc” for Payment Type.  DO NOT combine a renewal payment with any other payments for other items.
  
• If considering terminating one or more state securities registrations, reps must remember they are required to be securities registered in each of their securities customers resident states. In addition, they are required to be variable insurance licensed AND securities registered in each state in which they solicit insurance products.

Tips for a Successful Renewal Packet
To avoid any confusion or delays, please be sure that all renewal packets are complete.

• Return all pages to ESI as well as a mode of payment.
  
• Ensure rep’s name is provided on any checks submitted for payment.
  
• Please forward packets to ESI Licensing, with payment, as you receive them back. Do not wait until all are collected at the very end to send together. This helps ensure timely processing of renewals, and also helps ensure reps’ commissions are debited in a timely manner, if that is the mode of payment they choose.

Questions may be directed to ESI Licensing at ESI_Licensing@nationallife.com.

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From Touchstone Investments:

IMPORTANT NEW CONVERSION DATE
Touchstone Mutual Fund Conversion to Exchange-Traded Fund Q4 2023
Touchstone Dynamic Allocation Fund

The Special Meeting of Shareholders on October 2, 2023 has been adjourned to October 27, 2023 (the “Special Meeting”). Certain dates in connection with the Reorganization have been changed as noted in the table below to reflect a delay in the Reorganization.

On February 16, 2023, the Board of Trustees of the Touchstone Strategic Trust (“Trust”) approved converting the Touchstone Dynamic Allocation Fund (the “Target Fund”) into an exchange-traded fund (“ETF”) by the reorganization of the Fund into a new ETF (“Acquiring Fund”), which upon filing and regulatory approval will be a newly-created fund in the Touchstone family of funds, (the “Reorganization”). The Fund’s shareholders will be required to approve the Reorganization.

TA#	Existing Touchstone Fund Name	CUSIP	TICKER
3067	Dynamic Allocation Fund Class A	89154Q307	TSMAX
3068	Dynamic Allocation Fund Class C	89154Q406	TSMCX
3086	Dynamic Allocation Fund Class Y	89154Q505	TSMYX

• The Reorganization is expected to be tax-free for U.S. federal income tax purposes.
• In connection with the Reorganization, the Target Fund closed to new shareholders on May 15, 2023 and was closed to new purchases on September 29, 2023.
• After the Reorganization, shareholders may only purchase or sell shares of the Acquiring ETF on a national securities exchange at prevailing market prices through a broker-dealer.
• The Target Fund is sub-advised by Wilshire Associates Incorporated (“Wilshire”). The Acquiring ETF will be sub-advised by Los Angeles Capital Management LLC (“Los Angeles Capital”).

Effective Date (COB)	Conversion Events	Impact to Shareholders
9/29/2023	The Fund closed to new purchases	Purchase orders for trade dates 10/2/23 and beyond will not be accepted
11/1/2023	IRA/CESA accounts which have not moved to a Brokerage Account will be exchanged to the appropriate share class of the Touchstone Ultra Short Duration Fixed Income Fund.	If no action is taken prior to this date, all IRA and CESA accounts will be automatically exchanged to an appropriate share class of the Touchstone Ultra Short Duration Fixed Income Fund.
11/10/2023	Publicly available share classes will be consolidated into one share class.	Share classes will automatically consolidate into the Y share class.
11/15/2023	Last trade date to redeem shares of the Fund via NSCC.	Final trade date to redeem shares of the mutual fund or exchange shares for another mutual fund via NSCC.
11/17/2023	Reverse stock split occurs for the Y share class.	The total dollar value of a shareholder’s investment in the Fund will not change but the amount of shares owned will change.
11/20/2023	Last trade date to redeem shares of the Fund.	Final trade date to redeem shares of the mutual fund or exchange shares for another mutual fund.
11/27/2023	Fractional share liquidation.	Shareholders will receive a small amount of proceeds representing any fractional shares owned. This payment is taxable.
12/1/2023	Conversion from mutual fund to ETF.	Conversion from the Dynamic Allocation Fund to the

Should you have any questions, DTCC participant firms are invited to call BNY Mellon Broker Dealer Services at 877-332-2371. For any fund direct business or fund related inquiries, please contact Touchstone Shareholder Services at 800-543-0407.

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FOR BROKER DEALER USE ONLY

P.O. Box 534467 ● Pittsburgh, PA 15253-4467
ph 800.543.0407 ● fax 508.599.4066 ● TouchstoneInvestments.com
Touchstone Securities, Inc. ● Member FINRA and SIPC

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Join this ESI Social Media Compliance Webinar hosted by Jenna Simanskas, AVP Marketing & Communications, and Dan Hart, Compliance Advisor. We will review the ESI Social Media Policy’s main points and then respond to questions. Let’s discuss efficient practices to comply with the ESI policy as you connect with your audience.

You are invited to a Zoom webinar:

Please Register HERE
When: Oct 18, 2023 01:00 PM Eastern Time (US and Canada)
Topic: ESI Social Media Compliance
Click Here To Register

After registering, you will receive a confirmation email containing information about joining the webinar.

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Make it easy for clients and prospects to schedule time with you! Calendly’s online scheduling platform is now available to ESI Representatives.

Calendly Training Webinar
October 24, 2023
4pm ET
Register Here

About Calendly

• Easily share your calendar by including your personal Calendly link in your email, embedding it on your website, or sharing it through social media
• Streamlined booking – Clients can easily self-schedule meetings, and calls based on your availability. Reduces back-and-forth emails.
• Flexibility & Organization –Setting buffer times before and/or after meetings. Ensures you have time to prep for and organize your notes for each meeting.
• Customization – Tailor the type of meetings for your business and showcase all the services you have to offer. Each meeting can be customized including length, locations, reminders, and availability
• Automatic reminders – Scheduling services automatically remind all parties of upcoming booked appointments via email.
• Provide an easy way for clients to reschedule an appointment
• Availability at a glance – Your clients can see your real-time availability and schedule meetings around your availability.
• Mobile friendly – Scheduling can be done on-the-go via a simple website. No App needed! Great for your clients who are always on the move.
• Gift of time – Automated process reduces time spent on coordinating schedules and give you more time to meet with you clients      
• Client experience – Convenient online booking system provides an efficient and professional process for your clients.
• Analytics – View reports on meetings booked, cancelations, client history, peak booking times, and more.

How does Calendly work?
After you’ve set up your Calendly profile and sync it up with your Outlook calendar, you’ll receive a personal link that you can use on your emails, website, social media, etc.

Clients can simply click on your link to schedule a meeting with you. No more emailing potential times back-and-forth because you set the days and times that you want to make available for appointments.

How much does Calendly cost?
The Calendly service is $25 per month ($5.77 weekly) and will be deducted weekly from your commissions if you choose to use it. Currently, only the online scheduling service is available.

How do I get started?
To get started, click here for the Calendly Sign Up Form (note that you must be logged into the National Life website to access this form) and follow the directions.

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Field Notice 2023-22
September 20, 2023

ESI offers a text messaging solution to all field Registered Representatives (“RR”), registered administrative staff (“RA”), Investment Adviser Representatives (“IAR”), and non-registered fingerprinted persons (“NRF”) who use texting for business communications through CellTrust. All registered persons (i.e. RRs, IARs, and RAs) must register with CellTrust within 30 days of their affiliation with ESI. In accordance with SEC and FINRA rules, all electronic communications, including text messages, are required to be archived and reviewed by the Firm. To comply, RRs, RAs, IARs, and NRFs who use text messaging for business-related^[1] communications must download, activate and utilize CellTrust. Please note that personal text messaging services remain prohibited for business use.

The CellTrust application must be kept current by logging into it at least monthly.  Failure to do so will cause CellTrust to be made inactive.  If CellTrust is inactive, clients could text but the message will not be received, with no delivery failure message going back to the sender. 

Marketing And Advertising Disclosure

Going forward, all mention of a cell phone number on advertising materials (i.e. business cards, email signatures, web pages, etc.) will indicate whether or not texting is allowed. A personal cell phone number must indicate “Voice-Only.” CellTrust numbers will not require that disclosure. Prior to reprint, any hard copy materials must be submitted to the Advertising Guidance Team for review and approval. Digital materials should be submitted for the addition and approval of the new disclosure.

How Does It Work?

A mobile business number (“MBN”) can be used for both voice and text, or for text only. You may have a new MBN assigned to you based on your preferred area code and exchange (when possible), OR you may choose to use your existing landline number. To use an existing landline, you must currently have a business phone number that connects to a landline (versus a cell phone).

The CellTrust MBN or landline must be used to send and receive business text messages only. Please do not send personal text messages through the CellTrust MBN. 

Texts sent to an outside user (i.e. a non-CellTrust user) are not secure (i.e. encrypted). Therefore:

• Text messages must not contain personally identifiable information (“PII”) or any other data that requires encryption; and
• Text messages should never be used to obtain a customer’s personal or financial information.

When May I Start Using Celltrust?

As noted above, you may text clients once you are approved and have completed the setup of the CellTrust app. However, you may not text to any associated person (e.g. another RR, RA, NRF, or home office employee) until:

• You have completed the installation and activation of CellTrust
  AND
  The associated person has also completed the setup process (Note: If an affiliated person has registered and is active with CellTrust, you will be able to locate them in the CellTrust Directory.  If they don’t appear in the Directory, they are not active with CellTrust.)

Texting Prohibitions

Activities that are not allowed via text messaging include, but are not limited to:

• Sending or receiving Personally Identifiable Information (PII) such as birthdates, account numbers, social security numbers or any other such information;
• Sending or receiving account statements, applications, copies of drivers’ licenses or documents that include account numbers or sensitive information;
• Sending ‘Internal Use Only’ and corporate documents to other ESI associates;
• Business solicitations;

• Sending advertising or marketing material;
• Use of automated services to send bulk messages;
• Sending pictures or videos;
• Sending profanity or any other inappropriate language or images;
• Cold texting. Similar to cold calling, you must adhere to the Telephone Consumer Protection Act. Please review the Telephone Solicitation and Telemarketing Guidelines for details.

Costs

For RRs and IARs, the cost for CellTrust is covered by the ESI affiliation fee; for RAs, it’s covered by the administrative fee. If an NRF has a need to text for business purposes, which includes texting within the agency and/or to a RR, CellTrust is available to office staff for a fee of $25/month, paid by the RR.

Frequently Asked Questions:

Q1: I don’t text my clients. Why do I need to use CellTrust?

A1. Business-related communication encompasses more than just securities-related business messages sent to clients. It also includes investment advisory, insurance, and all business-related activities sent to/from clients, potential clients, vendors, home office employees, branch office staff, or other representatives.

Q2: I don’t have a smartphone. May I have an exemption? / Do I still need to use CellTrust?

A2: Yes. You can meet the requirement by logging into the desktop version of the app. You will still need to log in at least monthly to keep the account active.

Q3: What should I do if a client texts me Personally Identifiable Information (PII)?

A3: You can reply to the text, using the same thread, and remind them that 1) they should not send you PII via text message, and 2) they should utilize a secure email to send you any such information.

Q4: My clients sent a text to my personal phone number. How should I respond?

A4: Do not communicate with them from your personal device. Respond via email, or from your CellTrust number that you can only receive messages on that channel.

Q5: Do my NRFs need CellTrust?

A5: All affiliated individuals who text for business purposes must use the Firm’s approved platform. ESI will deduct the $25/month fee directly from the employing RR via commission deduction, but RRs may, at their discretion, pass the fee on to their NRF.

Questions

For technical issues, please contact the Help Desk at 802-229-3000. For questions regarding this Field Notice, please contact ESI Compliance at 800-344-7437 or by email at ESIElectroniccommunicatons@nationallife.com.

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[1] Includes anything relating to securities, investment advisory, all financial service-related activities including insurance, and all investment-related activities sent to/from clients, potential clients, vendors, home office employees, branch office administrative staff, or other RRs.

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Are you planning an in-person event? Would you like to use LinkedIn to promote your event? This ESI step-by-step guide will make it simple.

Click Here to Access the How-To Guide via Merrill
“Creating a LinkedIn In-Person Event”
Merrill #106906(0923)

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The Tax Cuts and Jobs Act expanded the definition of qualified education expenses to also include $10,000 for K-12 tuition, in addition to various college expenses.   

Share class selection within a 529 plan should factor in the intended use of the 529 and the anticipated timeframe for distributions starting, while considering the ongoing and long-term expenses associated with different share class options and the client’s best interest.   

Since distributions can now be utilized throughout the various education stages of the 529 beneficiary, and vendors have revised fee structures to align with Regulation Best Interest, ESI is updating the policy related using of C shares within 529 accounts.   

C shares will no longer be prohibited based solely on the 529 beneficiary’s age effective 10/1/2023.  In general, A shares should be utilized for younger 529 beneficiaries, unless the intended use is for K-12 tuition and anticipated to start within 6 years, or the C share option is more cost effective than the A share alternative.   

529 Municipal Securities Disclosure 

To assist you in documenting the intended use of 529 distributions and when they are anticipated to start, the 529 Municipal Securities Disclosure has been updated to include a new section that must always be completed and initialed by the client: 

The updated version should be utilized on all new 529 accounts, for existing accounts if it is not already on file, or if a switch is occurring.  Switching is recommending the sale of one 529 fund where a front-end or back-end load was paid, to buy another 529 fund with a sales load that could be avoided through the selection of a different fund.    

The Switch Disclosure section has also been updated.  Suitability Principals will continue to reach out to Registered Representatives (RR) when there is a missing 529 Municipal Securities Disclosure or if the switching language is missing, not complete or not acknowledged by the customer on the 529 Municipal Securities Disclosure for switching transactions.  

If the required information is not received after 30 days, ESI will send out a switch letter directly to the client. This letter will discuss what the customer needs to understand when deciding to engage in a Switch, specifically, that the new sales charge could have been avoided had they remained in the fund they just exchanged, or exchanged the investment for a new fund in the same fund family. In addition, an administrative fee of $250 fee will be assessed to the RR for failing to provide the required information within 30 days. Repeated missing or incomplete 529 Municipal Securities Disclosure may result in disciplinary action being taken.  

FINRA Fund Analyzer 

The FINRA Fund Analyzer comparing A vs C Share versions of the selected fund(s) will be required any time C shares are utilized within new 529 accounts when the intended use timeframe exceeds 6 years.  It will also be required on existing 529 accounts utilizing C shares when additional investments are made that exceed $1,000 and the intended use timeframe exceeds 6 years. 

You can access the FINRA Fund Analyzer through finra.org (For Investors > Tools & Calculators > Fund Analyzer) or https://tools.finra.org/fund_analyzer/.  

While FINRA no longer has a designated 529 version of the Fund Analyzer, the standard version does include some 529 specific funds when you search for them: 

If the 529 specific version of a fund isn’t available, you can still utilize the Fund Analyzer by selecting the regular version of the fund and then using the “Advanced Options” functionality to manually enter the different features such as Loads and Share Conversion that the 529 version would have:    

The completed Fund Analyzer should be uploaded into the Docupace work item and should also be provided to the client.  Do not use the “Share” function located within the FINRA Fund Analyzer. 

Existing 529 Accounts 

If an existing 529 account changes which share class is being utilized through new deposits or switches, then a new 529 Municipal Securities Disclosure should be completed.  Additionally, if an existing 529 account doesn’t have the current version of the 529 Municipal Securities Disclosure on file which identifies the intend use and timeframe the form may be requested by Operations.     

Breakpoint Checklist and Worksheet 

As a reminder, when the 529 Municipal Securities Disclosure form is completed, the client is attesting that you reviewed the Breakpoint Checklist and Worksheet (“Worksheet”) with them when purchasing Class A shares.  The Worksheet is not required to be submitted with paperwork to ESI for suitability review.  However, a copy of the Worksheet must be kept in the client file.  If you use Docupace as your client file, the Worksheet must be kept in Docupace.  A review of breakpoint worksheets is completed during branch examinations.  Failure to obtain copies of the Worksheet in your client file may result in examination deficiencies or disciplinary action.       

Dealer Changes 

If an existing 529 account is moved to ESI through a dealer change the 529 Municipal Securities Disclosure should be completed for both in-state and out-of-state scenarios. 

Questions

If you have any questions, please contact your supervisor or ESI Direct Business Suitability at 800-344-7437. 

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Today, consumers expect their Financial Professional to provide a wider range of solutions and expertise, so it’s no surprise that many Reps are turning to a teaming model to expand their business opportunities. To support Rep teams, ESI has established a Teaming Program that brings together the resources and information needed to establish and operate as a formal team.

Click Here to explore the new ESI Teaming Program site.

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