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FINRA Rule 3210 requires that associated persons disclose brokerage accounts held at a member firm other than their employer, which means registered persons must disclose to ESI reportable accounts held at another brokerage firm.  Accordingly, ESI has established electronic data feeds with several firms, through Star Compliance (“Star”), which allow the Firm to obtain account and transactional information on an automated basis. This allows your personal trading and holdings history to automatically populate your quarterly transactions and annual holdings certifications in Star.

The firms that provide automated data feeds include:

AmeripriseKestra FinancialStifel Nicolaus
Betterment SecuritiesLPL FinancialT. Rowe Price
Charles SchwabMerrill LynchTD Ameritrade
Chase Investment ServicesMML Investors ServicesUBS
CommonwealthMorgan StanleyUSAA
E*TradeNFSVanguard
Edward JonesPrudentialWealthfront
FidelityRaymond JamesWells Fargo
Interactive BrokersRBC Wealth Management
JP MorganRobinhood

What if my brokerage firm is not listed above?

Not all brokerage firms allow for electronic data feeds. If you hold an account at a firm that does not provide an automated data feed, there are four options for reporting:

  1. Move the account(s) to one of the firms listed above. 
  2. Attach statement(s) using the “Broker Account Statements” tile or the “To Do List” within Star Compliance (click here for directions).
  3. Attach statements to your Quarterly Transaction Report (QTR).
  4. E-mail account statements to ESICompliance@nationallife.com, Attention: Ben Zarzycki.

We will request duplicate paper statements from the holding firm.  However, if we do not receive them, we will reach out to you to obtain missing statements. It is your responsibility to assist in providing paper statements if the holding firm does not. Failure to provide account statements may result in disciplinary action.

How do i add a new brokerage account?

If you are interested in opening a new brokerage account with an outside firm, you need to obtain approval from ESI Compliance before opening the account. Contact ESI Compliance for an authorization letter – commonly referred to as a “407 letter”. ESI will provide the authorization letter, which you should attach to your new account application for the holding firm.

Once you have opened the account, complete the Authorization to Provide Account Information (ES0641) form, and email it to ESICompliance@nationallife.com. If the account is eligible to be added to a data feed, ESI Compliance will work with the holding firm to add your account to the feed.  If the account is not eligible for a data feed, ESI will request the holding firm provide duplicate paper statements.

QUESTIONS:

If you have questions about reportable brokerage accounts, transactions, or the process for obtaining approval for an outside account, contact Ben Zarzycki at 802-229-3659 or bzarzycki@nationallife.com.

Click Here to View Field Notice 2022-12 in Full

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