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.
If a report or document has a disclosure stating it is for “Qualified Client Use Only," then Cetera has certain 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 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 a report contains hypothetical portfolio performance, even if there is no 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 (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, the report (and the other financial planning output) must be included with the Financial Planning/Consulting Advice Summary Form CA 671.
Please contact the Prosperity Network Compliance Team with any questions: compliance@prosperityadvisors.com or 913-529-5500 Option 2.
Internal Use Only
Attachment: Form CA 925