Each year, Pinpoint Compliance automatically captures a list of the advisory accounts requiring an Annual Client Review (ACR). The annual client review calendar runs from January to December. Any account listed in the ACR Dashboard in Pinpoint must have a review completed by December 31. 2026 ACRs will be accepted into Pinpoint until 01/31/2027, but the actual review date must be recorded as having taken place in 2026.
Third party money-managed accounts may not be listed in Pinpoint. In that scenario, you are still required to complete an annual review and maintain documentation of the review in the client file or in your CRM.
Note: You are not required to complete an ACR in Pinpoint for advisory accounts that were opened in 2026.
What should you do if you are having trouble scheduling an annual review with a client?
Annual reviews should be conducted in-person, by phone, or via a remote meeting. If you are having difficulty scheduling an annual review meeting with a client, you can complete the review via email noting the following:
- There must be a "back and forth" discussion in the email chain. Each of the questions listed in the ACR module in Pinpoint must be asked of the client and the client must reply with their answers.
- There must be an exchange of information with the client so the advisor can answer all the questions in the ACR with certainty and with client verification.
- The advisor cannot answer questions about, as an example, changes to the client's financial situation or risk exposure without the client's input and responses within the email.
- A read receipt is NOT sufficient.
If you determine that an account is no longer suitable to be an advisory account:
- Advisors have the option of terminating the advisory relationship with an unresponsive client (or if there are other reasons why the account is no longer suitable to be an advisory account) by sending a termination letter, mailed to the client. The letter should be sent with a tracking number so you can confirm receipt. The letter needs to inform the client that the advisory agreement is being terminated and that the advisor will no longer monitor the account. A copy of the termination letter then must be emailed to the Cetera Advisory Services Dept (advisoryservices@cetera.com) and to compliance@prosperityadvisors.com. In the email, provide the client’s name and account numbers. Request that advisory billing be turned off immediately. Advisory Services will work with Brokerage Ops to convert the advisory account to a brokerage account. The account will no longer pay advisory fees and the account will no longer have discretion.
- There are scenarios when the advisor can temporarily turn off advisory billing, but eventually Advisory Services will need to know what the rep wants to do with the account. This could occur when you have not been able to contact a client in over a year and you are not able to manage the account until a proper review with the client has been completed. This is reviewed on a case-by-case basis.
What should I do if an ACR is NOT completed with the client by 12/31/2026?
- Please complete the ACR in Pinpoint (by no later than 1/31/2027) by answering “no” to indicate you did not meet with the client.
- In the comment box include the following:
- Explain why you did not meet.
- Provide the dates of the attempts to meet and the methods of contact. For example, “I contacted the client by phone on 2/23/26 and 6/30/26. I contacted the client via email on 7/31/26 and 9/1/26. I sent the client a letter with tracking on 10/15/26. The client did not respond to any of the attempts.”
- Assess if the account is still suitable to be an advisory account.
- If you have not been able to meet with the client in over 12 months, the account is most likely no longer suitable to be an advisory account. See the guidance above for how to notify the client and how to turn off the advisory billing in this scenario.
- Despite not meeting with the client in 2026, if you feel the account is still suitable to be an advisory account, include your reasoning within the comments section of the ACR in Pinpoint. For example, “The client has been difficult to reach in 2026 due to a medical diagnosis. I feel the account is still suitable to be an advisory account as I have been able to meet with the client each year prior and I am confident I will be able to meet with the client in January 2027.”
Job Aid Links:
ACR Progress Dashboard Job Aid
Feel free to contact the Prosperity Network Compliance team at 913-529-5500 Option 2 or compliance@prosperityadvisors.com with any questions.
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