Retail Full-Service Brokerage Business
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1 Retail Full-Service Brokerage Business This section is required if your firm engages in "full-service retail brokerage." This section is intended to help us better understand the risks and mitigating controls associated with your commission-based retail full-service brokerage business. *Are all registered representatives who interact with retail investors required to conduct all work related activities from company facilities?, in all cases, in some cases *How often does your firm reassess the investment objectives, risk tolerance and liquidity needs of retail customers beyond the initial account-setup process? te: We recognize that SEA Rule 17a-3 requires firms to attempt to update certain account information every 36 months. This question, however, is not intended to gauge compliance with SEA Rule 17a-3. Monthly Quarterly Annually Other (please specify) *Are transactions monitored in customer accounts for deviations from stated investment objectives?, in all cases, in some cases *Are cash balances from your client accounts swept nightly into an affiliated bank?
2 *Does your firm buy, sell or liquidate unregistered penny stocks/low-priced securities on behalf of its retail customers? (Please skip the following question) How does your firm receive its penny stocks/low-priced securities (select all that apply)? Via physical certificates DWAC (Deposit/Withdrawl at the Custodian) Other (please specify) N/A *Does your firm require customers engaging in unsolicited penny stocks/low-priced securities transactions to fill out a questionnaire regarding the source and nature of the shares? N/A
3 *Who prepares and distributes your firm's customer statements (select all that apply)? The firm prepares and distributes its own customer statements. An affiliate of the firm prepares and distributes customer statements on behalf of the firm. The firm's non-affiliated clearing agent prepares and distributes its customer statements on behalf of the firm. Other (please specify) *Does your firm allow its retail-facing registered representatives to engage in investment related outside business activities? *Does your firm employ an automated investment advice solution to assist its registered representatives with investment recommendations to retail customers? *Are managers of the sales platform compensated based on a percentage of the revenue the registered representatives under their supervision generate?, in all cases, in some cases
4 *Does the supervisor of the sales platform independently contact a representative sample of the retail customers of registered representatives under their supervision to periodically validate that customers are aware and approve of transactions executed on their behalf? *Does someone independent of the sales channel (e.g., audit, compliance) periodically contact a sample of retail customers of the firm to validate that customers are aware and approve of transactions executed on their behalf? *What is the ratio of registered representatives to supervisory personnel? te: Enter the number of registered representatives in the top input box and the number of supervisory personnel who are responsible for managing them in the bottom input box. *Registered Representatives *Supervisory Personnel *Are the supervisors who oversee the sales activity of retail customer facing registered
5 representatives located in the same facility as those registered representatives under their supervision?, in all cases, in some cases *Does your firm have producing managers who are responsible for supervising registered representatives who interact with the retail public? *Are the investment objectives of your firm's retail customers independently reviewed during the account-opening process (e.g., by someone other than the registered representative who handles the account)?, in all cases, in some cases *Can registered representatives update customer account profile information (e.g., contact information, home address, investment objectives) in the system of record without additional
6 approval or confirmation processes? *Does your firm obtain positive affirmation of customer address or other account profile changes?
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