ESI Closed Monday in Observance of Juneteenth Holiday

National Life Group and ESI – along with the NYSE and NASDAQ – will be closed on Monday, June 19, 2023 in observance of Juneteenth National Independence Day. Please be aware that many (if not all) of our strategic partners will be closed that day as well. We will re-open Tuesday June 20th with normal business hours.

While Juneteenth may be a newly federally recognized holiday, people in cities and towns across the U.S. have celebrated June 19th for a century and a half as on June 19, 1865, enslaved African Americans in Galveston, Texas were told they were free.  The announcement in Galveston put into effect the Emancipation Proclamation, which had been issued more than two and a half years earlier on January 1, 1863, by President Abraham Lincoln.  In recognition of Juneteenth, to honor the struggle for, and the progress made toward racial equity, National Life and ESI are adding this federal holiday to our list of office-closed holidays going forward.

Thank you for all you do for National Life and the communities we live in.

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Reminder: Touchstone Dynamic Allocation Mutual Fund Conversion Q4 2023

From Touchstone Investments:
As previously announced, 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.

In connection with the Reorganization, the Target Fund will close to new shareholders on May 15, 2023.

A Special Meeting of Shareholders is expected to be held in the third quarter of 2023 (the “Special Meeting”), at which shareholders of the Target Fund will be asked to vote on the proposal to approve the Reorganization. The Reorganization is expected to be tax-free for U.S. federal income tax purposes.

Current Target Fund shareholders may continue to purchase shares of the Target Fund until 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”).

Touchstone will distribute more details on the expected share class collapse and subsequent reorganization and in the coming months ahead of the event.

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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Reminder for Annuity Business in Florida

The Florida Department of Financial Services requires specific obligations to be met when conducting annuity business in their state.  While the requirements are not new, this notice should serve as a reminder and show how ESI has solutions to help ensure compliance.

These obligations outline that the agent, must have reasonable grounds for believing that the recommendation is suitable for the consumer, based on the consumer’s suitability information.  To assist with this requirement, they offer an Annuity Suitability Questionnaire form DFS-H1-1980.  This form is required for any annuity business occurring in Florida regardless of the client’s age.  ESI has added this document to our forms library.  Docupace StartingPoint will automatically add it to Florida annuity form kits as a required form effective 04/07/2023.

Additionally, Florida requires the Disclosure and Comparison of Annuity Contracts form DFS-H1-1981 to inform the client of material facts when a replacement transaction is occurring.  ESI has also added this form to our library; however, it will remain as an optional form that can manually be added to the forms kit when necessary. 

It is worth noting that these forms may also be needed for subsequent deposits into existing Florida contracts.  Rep’s assembling paperwork via Merrill will continue to be responsible for adding them when necessary. 

Please call Direct Business Suitability at 800-344-7437 with questions.  

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2022 IRA Contribution Deadline

Summary
The deadline for making a 2022 IRA Contribution is April 18, 2023. Please note, Emancipation Day in the District of Columbia (DC) will be celebrated on April 17th this year. As a result, April 17th is a holiday for federal government offices in DC and extends the tax filing deadline one business day to April 18th.

NOTE: The IRS has provided tax relief for residents of the following states due to various storms or natural disasters.

Check Processing Guidelines
To ensure Prior Year Contribution (PYC) checks are in good order and meet the 2022 contribution deadline:

  • The postmark on the original envelope must be on or before April 18, 2023
  • USPS metered mail stamps, if present, must be dated on or before April 18, 2023
  • For overnight mail: obtain a receipt from the overnight carrier showing:
    • Delivery Information
    • Date sent to ESI for processing
  • For checks hand-delivered to your office, maintain evidence that they were mailed by your firm to NFS on or before April 18, 2023
  • Avoid the use of prepaid business reply envelopes, as these do not provide proof of the mail date.

Mobile Check Deposit
The NFS process to code checks received after April 18th can be extremely cumbersome. Our Operations team receives this feedback every year after tax deadline.To avoid this frustration, do not mail checks to ESI Home Office for processing. Checks can be deposited via mobile deposit by the client via the Wealthscape Investor App, or by the Registered Representative/Admin Support staff via the Wealthscape App.

Important Notes

  • PYC checks received after April 18, 2023, will not be processed without proof that they were mailed on or before April 18th.
  • Checks deposited after April 21, 2023, must be booked as Current Year Contributions (CYC). If the check was intended as a PYC, ESI must submit the following documentation to NFS to modify the tax year:
    • Envelope in which the IRA contribution check was received. The postmark must be visible and be dated on or before April 18, 2023. Keep the envelope for firm records.
    • Copy of the IRA Contribution check along with accompanying documentation from the customer clearly indicating the intended tax year. This documentation can be in the form of a memo on the original check, or an attached letter of instruction.
    • Letter of instruction from customer must include check amount, date, account number and
      intended tax year.
  • Provided the request if properly documented, NFS will adjust the deposit made by ESI from a CYC to PYC, which in turn will automatically update the tax records for the impacted tax years.

Deadlines by Contribution Method

Electronic Funds Transfer (EFT)                        Loaded to ICP by April 18, 2023, 11:59pm ET
Bank Wire                                                        April 18, 2023, 6:00pm ET
Journal from Non-Retirement Acct           Loaded and approved by ESI by April 12, 2023, 11:59pm ET

Postponed Contributions Due to IRS Tax Relief
2022 IRA Contributions received after April 18th and are eligible for an IRS-granted tax filing extension relief must be processed as a CYC. The IRS requires contributions made after the federal tax filing deadline to be reported in Boxes 13a, 13b, and 13c of IRS Form 5498 as “postponed/late” contributions.

To adjust a contribution to report as postponed, please contact the Brokerage Operations department and provide verbal instructions.

Questions
If you have questions regarding the process for depositing Prior Year Contributions, please contact the Brokerage Operations desk at 1-800-344-7437.

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Forms Updates and New Client Resources from Brokerage Operations

New Client Resource!

Depositing Money into a Brokerage Account

Utilize this new digital flyer for clients on Depositing Money into a Brokerage Account.

Equity Services Inc. has prepared a new digital and download-friendly piece with instructions on the process for depositing money into a brokerage account. Click here to access the file, Catalog # 106629(0423).


Updates from Brokerage Operations

NFS Forms Update – CAT/CAIS Regulatory Requirements

ESI is required to report activity in Eligible Securities to the FINRA Consolidated Audit Trail (CAT) system. CAT tracks orders throughout their life cycle and identifies the broker-dealers handling them, thus allowing regulators to efficiently track activity in these Eligible Securities throughout the U.S. markets. The CAT Customer & Account Information System (CAIS) is a separate system for the submission of customer and account data, which is combined with the order reporting information.

Over the next few weeks, many NFS Brokerage Account forms will be updated in order to support CAT/CAIS regulatory requirements. All Applications, and other authorization forms, have been revised with the following:

  • Updated Taxpayer ID Number field to capture ITIN and EIN.
  • Added spaces to indicate if the account holder is an Accredited Investor (SEC.gov Accredited Investor Definition), employed/associated with a Registered Investment Adviser or a Broker-Dealer
  • Updated Entity Account Information to include a space to indicate whether the entity is an Accredited Investor, Registered Investment Adviser, Registered Investment Company, or a Broker-Dealer.

Forms will be updated to provide checkboxes allowing customers to provide this info. Boxes only need to be checked if these definitions apply to the customer. Form updates will include:

  • Brokerage Account Application
  • 529 Plan Account Application
  • Premiere Select Health Savings Account Application
  • Premiere Select IRA Application
  • Premiere Select SIMPLE IRA Application
  • Corporate and Unincorporated Resolution
  • Limited Liability Company Agreement
  • Partnership Account Agreement
  • Trustee Certification of Investment Power
  • Durable Power of Attorney Affidavit and Indemnification
  • Trading Authorization Forms

If you have questions on these form updates, please contact the Brokerage Service Desk at 1-800-344-7437.

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Reminder: Commission and Advisory Fee Payments

As Q1 closes, 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.

– Chris, Courtney, Katie, and Shane

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Delivery of Physical Certificates for Deposit to NFS

This notice serves as a reminder that ESI field offices and registered representatives (“RRs”) should not handle stock and certificates; certificates must be mailed by clients directly to NFS for processing.

DETAILS
RRs/IARs who have custody or possession of client securities or funds are subject to extensive regulation pursuant to SEA Rule 240.15c3-3(k)(2)(ii) for broker dealers and Rule 206(4)-2 under the Investment Advisers Act of 1940 for investment advisers. These rules define custody as “holding, directly or indirectly, client funds or securities, or having any authority to obtain possession of them.” ESI is exempt from these rules as long as ESI does not maintain custody of client funds or securities.

Field OSJs, branches and RRs should not accept stock and bond certificates or other negotiable documents. Instead, RRs should provide the customer with an envelope (which can be pre-postage stamped by the RR) and appropriate stock or bond power as described below.

It is considered acceptable for a representative to meet with clients to prepare or compile documents, including stock certificates, for forwarding to the qualified custodian (NFS). However, the client must be responsible for delivering such documents to the qualified custodian (NFS). The client should mail the securities documents directly to NFS. The office and/or RR will not take custody of any certificates, thus no entry of receipt needs to be noted on the Checks Received/Transaction blotter.

In the event that an RR inadvertently receives certificates from a client (e.g. mailed to the office or takes possession), follow the below process to return them:

  1. Promptly record receipt on the Checks Received/Transaction Blotter.
  2. Scan the following into Docupace using “ESI Inadvertent Receipt”: stock certificate(s), correspondence returning item to client, and the overnight package receipt with tracking number
  3. Reject the item(s) in Docupace (submitter rejects).
  4. Return to the client in-person or by overnight mail by noon of the next business day.

DELIVERY OF CERTIFICATES FOR DEPOSIT TO NFS
Client stock certificates should be sent to the address below with the NFS Stock or Bond Power Form. All account owners should sign and date the stock or bond power signing the certificate to NFS (for security reasons, do not have the client endorse the stock/bond certificate, rather, use the Stock/ Bond Power Form.

The Stock/Bond Power Form does NOT need to be sent to ESI for a Medallion Guarantee. This shall be handled by the NFS physical deposit team.

National Financial Services
Attn: Mail Zone KC1MO
100 Crosby Parkway
Covington, KY 41015

It is suggested that certificates be sent via certified mail and delivered with a signature required, or by some other traceable method. Physical Certificates should be in negotiable form and have no prior lien. If documents are submitted to resolved previous Not in Good Order (NIGO) issues, the Control Number must be referenced on the top border of the documents to avoid processing delays.

NFS Operational Processing Guidelines

Certificates in Good Order (“IGO”)

  • Certificates and related paperwork received IGO will be scanned by NFS.
  • An image of the certificate may be viewed in Wealthscape via the Imaged Documents section of the client’s account.

Certificates Not in Good Order (“NIGO”)

  • NFS notifies ESI of any items requires to resolve NIGO issues.
  • ESI will notify the RR and the RR is responsible for notifying the customers of the missing documentation.
  • Customer is responsible for forwarding required documentation to Covington, KY and referencing the control number on the documentation.
  • NIGO certificates for which a corresponding account number cannot be identified will be returned to the sender, if known, withing four business days. NFS will provide notification to ESI and ESI will notify the RR. If the sender is unknown, NFS shall return the certificate to the Transfer Agent.
  • NIGO certificates that have account numbers but require additional legal documentation will be credited to the account and may be reflected as a Legal Transfer item. When an item is in Legal Transfer Status (Type 4) an additional fee (Safekeeping Fee) of $15/month/certificate is charged to the account. If the legal documents have not been received within forty-five calendar days, the certificates will be returned to the account address of record via overnight carrier. Once a position is moved from Type 4 to Type 1, it becomes negotiable and there is a $100 Legal Transfer Fee charged to the account by NFS.

Restricted Stock

  • Certificates that are restricted shall only be deposited into a Customer account as described above on an exception-basis.
  • RR’s that receive a request from a customer to deposit Restricted Stock should contact the ESI Brokerage Trading Desk to seek approval to proceed with the transaction.
  • Standard process is followed to remove the restricted legend and clear the stock.

To Avoid Processing Delays

  1. Verify that the registration on the account is identical to that on the certificate.
  2. Verify that the certificate is valid. It is suggested, if there is doubt of that validity that the client call the transfer agent to confirm.
  3. Verify the required documentation is included.
  4. Verify the additional paperwork is included if the certificate is restricted.
  5. Verify all account owners signed and dated the stock or bond power signing over the certificate to NFS (for security reasons, do not have the client endorse the stock/bond certificate, rather, use the Stock/Bond Power).
  6. Verify the account number is referenced on the top right corner of the face of the certificate.
  7. Keep a copy of all documentation forwarded to NFS along with the date it was sent and the tracking number.

Questions
For questions about this notice, contact the ESI Brokerage Trading Desk at (800) 344-7437, option 2, option 3, option 1.

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