Off-Channel Communications continues to be a regulatory focus. Firms are being fined hundreds of millions of dollars for violations. Individual financial professionals are being fined as well.
- Texting outside of Cetera’s approved texting platform (MyRepChat) for business purposes is not permitted. This includes texts with clients, internal staff, colleagues, Prosperity or even Cetera home office.
- Use of WhatsApp for business purposes is never permitted.
- Chatting via Teams or other instant messaging for business purposes is not permitted. This includes chatting with internal staff.
- Business-related emails must be only via your approved Cetera email address. This includes emailing clients, internal staff, colleagues. You CANNOT send business-related emails to your personal email address. You CANNOT forward a business-related email to your personal email address, and you CANNOT cc your personal email address.
- Do not use any email address for securities or advisory business other than your approved Cetera email address.
- Examples off-channel communications that are NOT permitted include:
- Prohibited: Your admin texts you (outside of MyRepChat) and lets you know to check your emails.
- Prohibited: Asking a client to text you (outside of MyRepChat) as it is a very urgent matter.
- Prohibited: Using WhatsApp to communicate with a client as they are out of the country and do not have access to phone or email.
- Prohibited: Forwarding a MoneyGuide Pro report to your personal email address so you can prepare for an upcoming client meeting while you are at home.
- Prohibited: Chatting with internal staff via Teams as a way to quickly notify staff that a top client just walked in the door.
- Prohibited: Forwarding stock information from your personal email address to your business partner’s Cetera email address.
- Prohibited: Texting the OSJ (outside of MyRepChat) to ask about Cetera’s upcoming Awards Conference.
- Prohibited: Texting a client (outside of MyRepChat) to remind them of their upcoming appointment.
- What do I do if I receive a text from a client to my personal cell phone (outside of MyRepChat)?
- Do NOT reply to the text.
- You can reach out to the client via phone or from your approved email address.
- Take a screenshot of the text thread and upload it into Pinpoint as incoming correspondence.
- Notify the OSJ of what happened. compliance@prosperityadvisors.com
- MyRepChat is Cetera’s approved texting platform. It is now offered at no cost for financial professionals. To sign up, use the code: JYaJL.
For information on this solution, please click here: https://www.myrepchat.com/cetera-and-myrepchat/
Please contact the Prosperity Network Compliance Team with any questions:
compliance@prosperityadvisors.com or 913-529-5500 Option 2.
Internal Use Only