As part of our ongoing evaluation, we have identified strategies that will no longer be offered on the AssetMark platform. Advisors with clients invested in these strategies will receive the following information soon.
AssetMark, Inc. offers investment advisory solutions for you to better serve your client’s needs. Maintaining investment solutions that help investors meet their goals, complement one another on the platform, and meet our due diligence standards are an ongoing focus at AssetMark. Today we are notifying you of the strategies that will be removed from the AssetMark platform as a result of our ongoing reviews:
Altegris Futures Evolution Strategy Fund
Litman Gregory Global Standard and Tax Sensitive
Litman Gregory GuideMark ACE and Tax Sensitive
Model Capital Tactical US
Windham Adaptive Risk
AssetMark will stop accepting new accounts in these strategies after October 29, 2021. Existing clients can continue to access and add to their accounts. The strategies will be removed from the AssetMark platform on May 18, 2022.
Learn more about the designated replacement strategies and information on how these changes may impact your clients.
Review full announcement. If you have questions, contact your Strategic Accounts representative.
ESI’s 2021 Continuing Education Program for Advisors using the ESI Illuminations Flagship Select or Directions programs is now available on the FIRE Solutions website. Those required to take the course have received an e-mail welcome letter with further instructions on how to launch and complete this course.
The deadline for taking the course is October 31st, and this training is only required for Advisors who are acting as Portfolio Manager, have invested accounts in Flagship Select or Directions, and have not yet completed training in 2021. If you didn’t receive the welcome letter, you are NOT required to take this course.
Both the 2021 Annual Compliance Meeting (“ACM”) and the 2021-2022 Firm Element continuing education (“CE”) program are available in FIRE Solutions (“FIRE”) for all Registered Representatives (“RRs”).
Please note the due dates for completing the ACM and CE, as they are different:
Annual Compliance Meeting: complete by December 31, 2021
Firm Element CE: complete by February 28, 2022
2021 ANNUAL COMPLIANCE MEETING
Login to FIRE Solutions (see below for instructions) and scroll down on your dashboard to find the “ACMNow – On-Demand Meetings” section.
Click “Launch” to open the meeting in a new window. Ensure the volume on your device is working, as you must be able to hear the audio. As a reminder: ensure you complete the acknowledgement at the end of the presentation in order to receive credit for the meeting. If you don’t complete the acknowledgement, the system will not record your session as complete.
All registered persons will complete the following courses:
Outside Business and Personal Trading Activities: This course explains what is required when registered and associated persons wok outside their firm, deal in securities for others outside their firm, or invest for their own accounts outside the firm. It also provides case studies and disciplinary proceeding related to the topic.
Sales Practices for Senior Clients: This course reviews fraudulent and misleading activities discovered during regulatory examinations initiated by industry regulators, outlining how to recognize and what to do when a client displays diminished capacity or elder abuse.
Variable Annuity Sales Practices: This course highlights the suitability requirements and best practices to be considered when recommending and selling variable annuities.
FINRA: AML Your Role in Detecting and Deterring Money Laundering: This course covers concepts and strategies for detecting and preventing money-laundering activity.
SINGLE SIGN-ON (SSO) WITH FIRE SOLUTIONS
Use your NLG login credentials to access your agent portal. From the home page, find and click “NRS – FIRE Solutions” in the menu on the left of the screen.
This will bring you directly to your dashboard with FIRE. From there you can launch your Firm Element courses.
If, for some reason, you have a problem with SSO, you can still access your courses directly through FIRE’s website:
Go to https://blaze.firesolutions.com
At FIRE’s login screen, enter your username and password (provided in the email that you receive directly from FIRE).
If you do not receive an email with your username and password information, contact FIRE’s Student Mentor Team:
FIRE’s support hours are from 9:00am to 8:30pm ET, Monday through Friday. If you contact them outside of those hours, you will receive a response during the next business day.
FREQUENTLY ASKED QUESTIONS
How long do I have to complete the Annual Compliance Meeting?
The Annual Compliance Meeting must be completed by 12/31/2021.
How long do I have to complete the Firm Element courses?
The Firm Element courses must be completed by 2/28/2022.
What if I miss the due date?
A RR who has not completed the Annual Compliance Meeting by 12/31/2021 or the Firm Element courses by 2/28/2022 may be subject to disciplinary action.
How do I pay for my courses through FIRE?
The cost of the Firm Element courses is covered in the ESI affiliation fee. You will not have to pay separately for your Firm Element courses.
Am I required to complete the Firm Element courses?
Covered Persons, as defined under FINRA Rule 1240(b)(1), are subject to the Firm Element CE program. At ESI, Covered Persons include all RRs in the field, and home office personnel working within ESI (registered and non-registered), and certain National Life employees registered as Operations Professionals.
Do I have to complete the Firm Element courses if I join ESI mid-year?
RRs whose ESI affiliation is active prior to 7/1/2021 must complete the program. Those whose ESI affiliation is active on or after 7/1/2021 are exempt from the current year’s Firm Element CE program
What if I recently completed FINRA’s Regulatory CE Session?
Regulatory Element training is an online exam administered by FINRA and must be completed on certain anniversaries of initial registration. Firm Element training is an annual requirement administered by the broker-dealer and must be completed in addition to the Regulatory Element. Both are required elements of FINRA’s overall CE requirement.
Can I obtain insurance CE credit through FIRE Solutions?
Yes, your subscription to FIRE Solutions gives you access to their catalog of insurance CE courses, as well. You will be responsible for the cost of courses purchased to fulfill insurance CE requirements, and FIRE will bill you directly. Additional fees for CE credits may vary depending on the state(s) requested.
What if I am having system issues?
For technical assistance with the FIRE Solutions website or questions on insurance CE credit, please contact the Student Mentor Team at 1-866-ASK-FIRE x1, or by email at firesupport@nrs-inc.com.
Will my courses through FIRE Solutions fulfill certain National Life requirements?
No, National Life maintains a separate AML requirement, apart from ESI’s Firm Element curriculum. Your National Life Annual E&O update and AML renewal can be easily updated in one system. Please contact National Life’s Market Conduct and Compliance group for information on taking the 2-year AML renewal for National Life.
QUESTIONS
If you have additional questions regarding these programs, please feel free to contact the individuals below:
Beginning in October, ESI Brokerage Account customers will begin receiving a NEW enhanced statement format! The new statement format will apply to all Monthly/Quarterly and Annual statements for NFS Brokerage and ESI Illuminations accounts.
The enhancement corresponds closely to the roll-out of the quarterly paper statement surcharge. This may be a good opportunity to reach out to customers, explain the improved formatting of their statements and encourage them to enroll for eDelivery to review online at the Wealthscape Investor portal.
What’s changing?
The holdings section is being enhanced to display client investment and a new disclosure, when applicable. Client investment will represent the sum of the purchases made for a given security where purchases are defined as Buys, Transfers and Conversions. Please note, transfers and/or conversions must have customer or third-party provided basis.
Enhancements include the following:
• A new disclosure will appear at the beginning of the holdings section and will include the definition of client investment.
• Client investment amount will display within the security description if it meets the definition criteria above.
• The client investment information will not display if the definition criteria is not met.
• Sub-total for each major asset class will display the sum of client investment for each security within that holdings sub-section.
• Overall total for client investment will display at the end of the holdings section.
Screenshots of Changes highlighted in yellow
Holdings: Proximity Disclosure for Client Investment – Client investment Disclosure is in holdings section which provides the definition of “client investment”
Holdings: Client Investment at the Holdings Level – Client investment will be available in Holdings for each position within the description column.
Holdings Sub-Categories: Overall Client Investment Totals by Sub-Category – Client investment totals at the sub-category level are being provided where applicable.
Holdings: Overall Client Investment Total – Overall client investments total for the holdings section is being provided where applicable.
Automated Wealthscape RMD Report
Throughout the last quarter of 2021, ESI Operations will deliver an automated reporting alert to your NL email address to assist in managing RMD’s for your NFS Brokerage account customers.
On or around the 15th of each month during Q4 the report will be triggered. The automated email contains a hyperlink that will launch the report if you are logged into Wealthscape. If you are not logged in, you will be asked to enter your credentials.
The report has been filtered to show accounts with an “estimated RMD amount remaining” of greater than zero. This will NOT show clients who have already satisfied their RMD for a specific account this year. The report also contains an indicator that shows whether the customer has a periodic plan set up on the account, and the remaining amount scheduled to pay as part of the plan.
Please proactively raise cash for the periodic plans if cash is not currently available. Failure to do so could cause the plan to fail and expose the client to potential penalties on amounts that were not distributed by the 12/31 deadline.
Please contact our service desk at 1-800-344-7437 with any questions.
November 1, 2021 Deadline Report Retention Update in My View Portal
On November 1st Broadridge will be modifying the retention time on the reports available within My View Portal. These reports include, but are not limited to, Rep Commission Statements, Trail Detail, and Sales Blotters. We will be shifting to a three-year retention, removing the history of these reports beyond that time period, which will free up space within the system and help alleviate latency issues that come along with increased storage amounts.
We are communicating in advance of this change so that you may download any historical reports you’d like to save for your records.
If you have any questions on this retention update, please reach out to ESI Commissions at 800-344-7437.
November 1st – 19h, 2021 – 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, 2021 – Maintenance Fee Waiver Request Deadline – Representatives must submit the Maintenance Fee Waiver Request Form by November 15th to absorb fees for their clients.
November 22, 2021 – Collection Day – Unpaid fees are posted to customer accounts. Accounts with insufficient cash will result in a cash debit balance.
November 22, 2021 Deadline 2021 Premiere Select Retirement Accounts: Annual Maintenance Fee Cycle National Financial Services will be charging Premiere Select Retirement accounts the annual $40.00 retirement maintenance fee on November 22nd, 2021. Review all the details here.
January 5th, 2021 through January 31st, 2021 – 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).
Envestnet has recently updated their sales support team map. To access it, simply log in to ESI Illuminations and click on the Platform. You’ll find the new sales map under the General Resources section.
Touchstone Fund Name Change & Strategy Change effective October 28, 2021
Touchstone Ohio Tax-Free Bond Fund name change to: Touchstone Core Municipal Bond Fund
TA#
Existing Touchstone Fund Name
CUSIP
TICKER
TA # No Change
New Touchstone Fund Name
CUSIPNo Change
TickerNo Change
9
Touchstone Ohio Tax-Free Bond Fund Class A
89154V603
TOHAX
9
Touchstone Core Municipal Bond Fund Class A
89154V603
TOHAX
14
Touchstone Ohio Tax-Free Bond Fund Class C
89154V702
TOHCX
14
Touchstone Core Municipal Bond Fund Class C
89154V702
TOHCX
519
Touchstone Ohio Tax-Free Bond Fund Class Y
89154V843
TOHYX
519
Touchstone Core Municipal Bond Fund Class A
89154V843
TOHYX
569
Touchstone Ohio Tax-Free Bond Fund Inst Class
89154V835
TOHIX
569
Touchstone Core Municipal Bond Fund Institutional Class
89154V835
TOHIX
On May 20, 2021, the Board of Trustees of the Touchstone Strategic Trust approved a proposal for the following changes to the Touchstone Ohio Tax-Free Bond Fund (the “Fund”): a name change for the Fund to the Touchstone Core Municipal Bond Fund, the appointment of Sage Advisory Services, LTD. Co as sub-advisor to the Fund, changes to the Fund’s investment goal, fundamental investment policy and principal investment strategies, and certain fee reductions (together, the “Repurposing”). Part of this proposal was subject to shareholder approval.
UPDATE: At the Special Meeting of Shareholders held September 30th, shareholders of the Fund approved the proposal and the changes will be effective on October 28, 2021. There will be no changes to the TA numbers, CUSIPs or Tickers. Please reference the chart above.
Touchstone will distribute a final reminder closer to the effective date.
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.
FOR BROKER DEALER USE ONLY
P.O. Box 9878 ● Providence, RI 02940-8078 ph 800.543.0407 ● fax 508.599.4066 ● TouchstoneInvestments.com Touchstone Securities, Inc. ● Member FINRA and SIPC
ESI’S 2021 FEEDBACK JOURNEY In 2021 ESI’s goals are focused on the growth of our business as well as increasing the number of representatives partnered with us. To achieve these goals, we need confidence that we are providing the best in products and service to all of our field partners. It is our belief that this confidence can only come from getting feedback from our partners we serve, you. Feedback is key for us to learn where our strengths are, where there is room for improvement, and how best to move forward with achieving our goals in 2021.
If you recall, earlier in the year we sent out what we called a Sentiment Survey to representatives in the field, to get a baseline on how ESI is doing at a very high level. We wanted to assess your experience in working with ESI holistically.
Today, we are drilling down a bit and putting our focus specifically on the ESI Compliance department which includes: Investment Advisory Compliance, Electronic Communications, Surveillance, Branch Examinations, Licensing and Registration, Complaints and Regulatory Matters, Continuing Education Programs, Incentives, Gifts and Entertainment. Feedback related to Advertising or Suitability Review should not be included, however our management team is ready to listen should you have a specific issue to discuss.
ESI COMPLIANCE SURVEY The goal of ESI Compliance is to protect our stakeholders through a solution-driven mindset that prioritizes innovation as a competitive advantage. We strive to provide the best possible service to help you, our partners in the field, grow your business and help your clients achieve their financial goals. We appreciate you helping us toward attaining this goal and being better compliance lifeguards.
With your feedback we can better understand our strengths and weaknesses. It will also allow us the opportunity to correct actions that aren’t helpful and make sure we repeat those that are. After all, your success is our success.
WHO IS ESI COMPLIANCE? ESI Compliance is made up of a team of compliance lifeguards. Lifeguards scan the waters for danger and educate swimmers of the rules to protect them from harm. Compliance performs these functions in the investment world, protecting the Company from regulatory “danger” and helping employees and registered representatives avoid getting in over their heads.
Your ESI Compliance Team is made up of the following people:
Scott Solod, Rob Lewton, Tom Longfellow, Laura Plourde, Kyla Ward, Penny Vinson, Misty Dodson, Angela Pedley, Gail Woods, Sharlene Mazza, Eric Hopkins, Ben Zarzycki, Stephen Wiggins, Tonya Carrien and Christine Embling.
THANK YOU We would like to thank you in advance for taking a few minutes to complete the ESI Compliance Survey, as well as any additional Surveys you may be sent throughout the year. We truly believe this feedback will play an important role in helping all of us to reach our goals and be successful.
Regulation Best Interest (“Reg BI”) introduced a new disclosure document, Form CRS (Client Relationship Summary), which has specific delivery and record retention requirements. This Notice is to serve as a reminder as to the requirements for the Form CRS acknowledgement form.
When Form CRS is Required
For new customers:
For new brokerage and direct business customers, Form CRS must be delivered prior to or at the time of:
Opening an account or changing the broker/dealer on a direct business account;
Recommending an account type, securities transaction, or investment strategy that involves securities (e.g. recommending a customer open a brokerage account, or purchase a specific security or variable product), or
Placing an order for the retail investor.
For new advisory clients, the Form CRS must be delivered prior to or at the time of entering into an advisory contract with the investor.
Required for co-advised (Illuminations, Directions, Morningstar, and SEI, Schwab Retirement Advisor Services, and American Funds Retirement Plan Solutions),
Only required for solicitor accounts when there is a recommended rollover.
For Existing Customers:
Reg BI specifies certain other instances which trigger subsequent delivery requirements. Form CRS must be delivered to existing customers when you:
Open a new account that is different from their existing account(s);
Recommend a rollover from a qualified plan into a new or existing account;
Recommend or provide a new brokerage or advisory service or investment that doesn’t necessarily involve the opening of a new account and would not be held in an existing account (e.g. ownership changes).
These subsequent delivery requirements apply to both broker-dealer and advisory customers.
Acknowledgement of Form CRS Delivery Form
Generally, recommendations, account establishment, and trading orders occur in conjunction with completing some form of account paperwork. Therefore, Form CRS is included in the new account kit available through Docupace Starting Point. If you do not use Starting Point, you must ensure the Form CRS is the first document provided to the customer when completing new account paperwork.
Prospective Customers Who Do Not Open an Account
If, prior to actually providing account paperwork, you make a recommendation that triggers the Form CRS delivery requirement to a prospective customer (i.e. an investor who doesn’t already have a business relationship with ESI), you must provide them with the Form CRS, and then you must document delivery by completing the Acknowledgement of Form CRS Delivery (“Acknowledgement”), which is bundled with our Form CRS (please refer to ESI Form ES0717). The Acknowledgement form is a record of delivery and must be retained for six years from the date of delivery, in accordance with the instructions provided below (see “Form CRS prospective client file”).
Form CRS Prospective Client File
Prospective customers will not yet have an established Docupace client file. Therefore, the acknowledgement for prospective clients will be maintained in print form in a Form CRS Prospective Client File. The Form CRS Prospective Client File is a required book and record to be maintained in all branch offices and FOSJs (similar to the Complaint File or the Seminar File).
If you complete an Acknowledgement for a prospective customer, ensure the Acknowledgement is added to the Form CRS Prospective Client File in your branch or FOSJ (which ever you are located in).
There is no requirement to submit the acknowledgements to your FOSJ if you are in a detached branch office, or for your supervisor to approve them.
Acknowledgements are to be maintained in the branch file as a record of delivery. The file will be subject to review during office examinations.
The Acknowledgement must be kept for 6 years from the date of delivery, regardless of whether or not the individual ever opens an account through ESI.
If the prospect becomes a client, add the Acknowledgment to their Docupace client file. It would be acceptable to submit the acknowledgement along with the new account paperwork when they become a client.
