THE 360 NEWSLETTER

Client notes tell the story behind the documents in your client files and should be written in a manner that will help defend your recommendations should they be looked at by regulators or anyone else.

Inadequate client meeting notes continues to be a frequent audit deficiency, therefore we wish to remind you that you are required to document notes for every meeting with a client, regardless of whether a trade resulted from the meeting or not. Additionally, copies of notes must always be available in the “Notes” section of Univeris or sent to imaging. It is also recommended that you maintain a record of unsuccessful attempts to contact/meet with the client to evidence your efforts in meeting your obligations to the client.

Adequate meeting notes must contain:

• Details (answers to who, what, where, when, why);
• Client-specific information rather than using general statements like “reviewed accounts” or “the client agrees to trade recommendations”;
• Follow-up or action to be taken as a result of the meeting (e.g., “No further action required at this time. Next meeting to be scheduled for November 2022”).

If a trade recommendation is made during a client meeting, the notes are also required to contain:

• Which funds are being purchases, switched or redeemed, and in which account (be specific);
• Whether trades requested by the client were executed, cancelled or modified;
• Confirmation of discussion of any fees, trailers or commissions to be paid;
• Source of funds for purchases over $50,000;
• Reason for redemption;
• Instructions as to where the proceeds of a redemption are to be sent or how they are being reinvested;
• Confirmation of how and when Fund Facts were delivered if not sent through Univeris Fund Facts module.

For more information, we refer you to Investia’s Compliance Policies & Procedures Manual (Chapter 4, Section I M – Maintaining Client Notes), as well as the memo Note-Taking Requirements released in the The 360 Newsletter on November 18, 2021.