All client report templates require Pre-Approval AND Qualified Client Process
We were recently advised by Cetera Ad Review management that all report templates (even if from approved vendors such as eMoney, Asset Map, MoneyGuidePro, Holistiplan and Nitrogen) require Pre-Approval from Ad Review in Pinpoint.
Before you use any report with a client (including reports from Cetera-approved vendors), make sure you have a current Ad Review approval for that report template. Ad Review Pre-Approval is required before providing a copy of the report to the client via mail or email as well as prior to allowing the client to view the report on a screen. Templates are subject to Advertising sunset periods, so they should be resubmitted for approval according to the sunset date.
Take care that the report you use with a client “matches” the approved report template. If you add or remove a section of the approved report template, then it is considered a “material difference” and the revised report template requires a separate approval. If you add or remove a chart, that is also considered a “material difference” and the revised report template requires a separate approval. In our most recent audit, the auditors compared the approved report template to the report provided to a client via email page by page looking for differences.
If a report or document has a disclosure stating it is for “Qualified Client Use Only” (or something similar), then Cetera has additional requirements:
- The report template must be pre-approved by Ad Review in Pinpoint.
- The Qualified Client Form CA 925 must be completed documenting the recipient meets the definition of a qualified client.
- A copy of the Qualified Client Form CA 925 along with a pdf file of the deliverable/client-specific report must be submitted into Pinpoint Ad Review for documentation. Please add a comment to the submission indicating the Reference number for the approved report template.
- You can immediately provide the report to the client if the report template was pre-approved. You do not have to wait for Ad Review to respond when submitting the Qualified Client Form CA 925 with the client-specific report.
- Some reports may state it is permitted to provide the report to “non-qualified” clients if the report is provided as part of financial planning output. In this scenario there must be a signed Financial Planning agreement in place. The report (and the other financial planning output) must be included with the Financial Planning/Consulting Advice Summary Form CA 671.
If a report contains hypothetical portfolio performance, even if there is no “Qualified Client” disclosure, the SEC Marketing Rule requires that the report only be provided to qualified clients or as part of approved financial planning output to a financial planning client.
- The report template must be pre-approved by Ad Review in Pinpoint.
- If providing to a qualified client (and it is NOT part of financial planning output), the Qualified Client Form CA 925 must be completed to document the recipient meets the definition of a qualified client.
- If providing to a qualified client (it is NOT part of financial planning output), a copy of the Qualified Client Form CA 925 along with a pdf file of the deliverable must be submitted into Pinpoint Ad Review for documentation. Please add a comment to the submission indicating the Reference number for the approved report template.
- If provided as part of financial planning output, there must be a signed financial planning agreement in place. The client-specific report (and the other financial planning output) must be included with the Financial Planning/Consulting Advice Summary Form CA 671.
REMINDER: It is important to review the disclosures listed on any report or document prior to providing the document to a client. If there are disclosures such as “Financial Professional Use Only”, “Broker-Dealer Use Only”, “Agent Use Only”, etc. those reports CANNOT be provided to or shown to a client at all.
** For ease of use, we have created a quick reference checklist, attached below.
Please contact the Prosperity Network Compliance Team with any questions: compliance@prosperityadvisors.com or 913-529-5500 Option 2.
Attachments: Form CA 925 and Client Reports Checklist
Internal Use Only