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Compliance & Licensing

Additional Investments in Docupace AND Municipal Bond Transaction Procedures

By October 6, 2020No Comments

Rule G-47 requires brokers, dealers and municipal securities dealers (collectively, “dealers”) to disclose to their customers, at or prior to the time of a municipal bond trade, all material information known about the transaction, as well as material information about the security that is reasonably accessible to the market. Information is considered to be material under Rule G-47 if there is a substantial likelihood that the information would be considered important or significant by a reasonable investor making an investment decision. The rule currently includes a non-exhaustive list of information that is generally considered material, including OID and other factors.

CLICK HERE TO READ MORE – FN2020-37

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All checks and paperwork for additional deposits/transfers into existing investments are required to be added to the blotter and submitted for review in Docupace whenever you:

  • Propose/suggest that a client add funds to their investment;
  • Review the investment with your client and an additional investment results;
  • Handle a client’s check/transfer form;
  • Help a client fill out paperwork for additional investment, including for a transfer; or
  • Recommend liquidation of a financial product to fund the additional investment.

Generally, unless the client is truly acting on their own and you are not involved with the transaction, the subsequent investment must be placed through the Firm. For more details, please review the Additional Investment and Documentation Requirement Matrix.

As a reminder, check distributions from NFS brokerage/advisory accounts to direct business accounts where ESI is broker dealer of record must to go through separate Docupace workflows. 

  • The check distribution is handled by ESI’s Brokerage team.
  • The principal review and approval of the direct business deposit is handled through a separate work item by the Direct Business team and is subject to the Additional Investment Matrix above.

CLICK HERE TO READ MORE – FN2020-38

TC117341(1020)1