eSignature Update
Effective immediately eSignature can be utilized through Docupace/DocuSign for Allianz business in the state of New York. All paperwork available in Docupace for Allianz can now be electronically signed, without any state level restriction.

The current list of all eSign approved vendors can be found here.

If you have any questions, please call 800-344-7437 or email DocupaceSupport@nationallife.com.

New HSA Registration Available for NFS New Account Opening
To continue the enhancement of the guided account opening within Docupace, we’ve added the ability to create Health Savings Accounts (HSA) via the current NFS New Account tile. In addition, new accounts for the NFS – Health Savings Account registration type can be opened immediately via the New Account Opening integration between Docupace and NFS. This is especially useful when you need the new account number to rollover an existing HSA.

For information regarding the use of the New Account Opening integration, please refer to the following guides:

Initializing a Token for the NFS Account Opening Integration

NFS Account Opening

If you have any questions, please call 800-344-7437 or email DocupaceSupport@nationallife.com.

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To continue the enhancement of the guided account opening within Docupace, we’ve added the ability to create Health Savings Accounts (HSA) via the current NFS New Account tile. In addition, new accounts for the NFS – Health Savings Account registration type can be opened immediately via the New Account Opening integration between Docupace and NFS. This is especially useful when you need the new account number to rollover an existing HSA.

For information regarding the use of the New Account Opening integration, please refer to the following guides:

Initializing a Token for the NFS Account Opening Integration

NFS Account Opening

If you have any questions, please call 800-344-7437 or email DocupaceSupport@nationallife.com.

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Effective immediately eSignature can be utilized through Docupace/DocuSign for Allianz business in the state of New York. All paperwork available in Docupace for Allianz can now be electronically signed, without any state level restriction.

The current list of all eSign approved vendors can be found here.

If you have any questions, please call 800-344-7437 or email DocupaceSupport@nationallife.com.

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Overview of MSRB Rule G-47
Rule G-47 (“Rule”) 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 if there is a substantial likelihood that the information would be considered important or significant to a reasonable investor’s decision to invest. The Rule currently includes a non-exhaustive list of information that is generally considered material, including OID and other factors.

Municipal Bond Transaction Disclosure Checklist
To assist you in complying with this requirement and documenting the sources used for disclosure, ESI Operations has created a Municipal Bond Transaction Disclosure Checklist.

The checklist is required on all transactions (both buy and sell orders, whether solicited or unsolicited) and must be uploaded to the applicable client folder in Docupace. The form should be completed at time of trade and uploaded by the end of the trade date. ESI’s trading group reviews this activity on a T+1 basis and will periodically reach out for this form if it is not filed in Docupace.  Failure to upload the form within the required timeframe could result in reversal of any mark-up/down on the associated transaction(s) and could result in additional disciplinary action by the Firm.

Please note that information sources used to make required disclosures to the customer must be maintained in the representatives’ client file. If the client file is solely maintained electronically in Docupace, the information sources used must be uploaded into Docupace.

Questions
If you have questions regarding the procedure for Municipal Bond Transactions, please contact the Trading Desk at 1-800-344-7437.

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From Fidelity:

This week, SECURE Act 2.0 is expected to be signed into law as part of a larger government spending package. SECURE Act 2.0 includes many provisions designed to help Americans save for retirement. Most provisions included in SECURE 2.0 go into effect in 2024 or later. SECURE Act 2.0, however, did include changes to RMD rules that become effective on January 1, 2023. Most immediately impactful is the required beginning age for RMDs being increased from age 72 to 73.

Fidelity will update RMD systems to exclude IRA and Retirement Plan account owners turning age 72 in 2023 from RMD calculations and services. Fidelity will also ensure these account owners do not receive RMD notification as part of the annual Form 5498 tax process. Fidelity is currently conducting analysis of the SECURE Act 2.0 provisions and determining plans to address additional areas of impacts for the RMD age change, including forms, agreements, marketing materials, P&Ps, Online Reference, and reporting.

Fidelity will not make any updates to RMD Systematic Withdrawal Plans already established for any clients turning age 72 in 2023.

Note from ESI: Registered Reps should review these distribution plans and confirm that clients still want to receive distributions in 2023.  If any changes need to be made to existing periodic withdrawal plans, please contact ESI Operations at 800-344-7437.

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In 2019, ESI restructured our commission grid, creating a total of eight target production bands. This update helped provide achievable goals for our Registered Representatives, maintain best in class payouts, and ensure the revenue necessary to sustain the company’s, product, technology and service offerings.

In alignment with these goals, the Firm will be raising the bar on target production, beginning January 1, 2023.

Please consult with your Branch Office Supervisor for your current payouts associated with each tier or view your payouts on the NL Agent Portal. The updated tiers are listed below as well as a screenshot of the the ESI Commission Portal (ACE) location. There are no changes to the EFA Managed Money grids.

2021 Versus 2023 Base Grid Comparison

ESI Commission Portal (ACE) on the NL Agent Portal

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Looking for NL application processing deadlines? Click here.

For important reporting updates for RMDs and annual retirement account fees, click here.

ESI BROKERAGE OPERATIONS – IMPORTANT DATES

Jan. 5-31, 2023 
Securities Liquidations to cover Unpaid Fee Postings – ESI home office will begin the process of liquidating securities to cover unpaid fee postings related to the NFS IRA Custody Fee and non-qualified “Inactivity Fee”. Accounts with eligible securities will have trades placed to cover “debit” balances related to fee postings, as well as applicable transaction charges. Customer confirmations will be marked “To Cover Debit”. Representative’s will be charged the $25.00 service fee if ESI home office has to place trades.

Please contact ESI Operations at (800) 344-7437 with questions.

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Fidelity Notice 22-297:

The IRS recently released Notice 2022-53 that provides guidance relative to certain RMD rules enacted by the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019. The notice also announced that the Department of the Treasury and the IRS will issue final RMD regulations effective no earlier than the 2023 distribution calendar year which, to date, have not been released in final form.

Beneficiary 10-Year Rule

The SECURE Act generally imposes a 10-year deadline for making distributions to beneficiaries of defined contribution retirement plan (DCRP) accounts and IRAs who are not “eligible” designated beneficiaries (EDBs). This 10-year rule is effective for beneficiaries of individuals who died after December 31, 2019. There has been considerable confusion about the scope of the 10-year rule, namely, whether or not distributions are required each year throughout the 10-year period. Pursuant to Notice 2022-53, the proposed regulations provide that distributions indeed must be made each year during the 10-year period (1) for any designated beneficiary if the original account owner dies on or after their required beginning date (RBD) for taking distributions because the “at-least-as-rapidly” rule of Code section 401(a)(9)(B)(i) applies in such case, (2) following the death of an EDB who, pursuant to Code section 401(a)(9)(B)(iii), is “stretching” the benefits they inherited from the original account owner who died before the RBD, and (3) when a minor child beneficiary reaches the age of majority who pursuant to Code section 401(a)(9)(E)(iii), will no longer be considered an eligible designated beneficiary.

10-year rule scenarios covered by the notice:

(1) Generally, a designated beneficiary who is not an EDB and who inherits the account on or after the original owner’s RBD, is required to take annual distributions with the entire interest distributed by the end of the calendar year that includes the tenth anniversary of the date of the original owner’s death.

(2) A successor beneficiary of an EDB who was taking life expectancy distributions, is generally required to take annual distributions with the entire interest distributed by the end of the calendar year that includes the tenth anniversary of the date of the EDB’s death.

(3) A minor child beneficiary who reaches age of majority, is generally required to take annual distributions with the entire interest distributed by the end of the calendar year that includes the tenth anniversary of the date the minor child reached age of majority.

50% Excise Tax Relief for 2021 and 2022

Notice 2022-53 also provides relief for failures in 2021 and 2022 to comply with the recent IRS interpretation of the 10-year rule. Under the relief, a DCRP that failed to make a “specified RMD” will not be treated as having failed to satisfy section 401(a)(9) merely because it did not make the required distribution. Likewise, to the extent that a beneficiary failed to take a “specified RMD,” the IRS will not impose the 50% excise tax that otherwise applies to RMD failures. In this instance, a beneficiary who paid an excise tax for 2021 can get a refund.

Important: The above relief only relates to beneficiaries subject to the 10-year rule, not to beneficiaries eligible to take true life expectancy distributions.

ICP 10-Year Periodic Withdrawal Plan

The Integrated Cashiering Platform (ICP) was enhanced earlier this year with an “Inherited 10 Year” periodic distribution plan type specifically for Inherited IRAs, also known as IRA Beneficiary Distribution Accounts (IRA-BDAs). The Inherited 10 Year plan was designed to distribute the entire account balance by the distribution plan’s end date, which is on December 31 of the 10th year after the original IRA owner’s date of death.

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