Author Archives: Tammy Case

New TFS Securities Alternative Investments Disclosure

TFS Securities, in an effort to serve our clients and remain fully compliant with Federal and State regulations concerning Alternative Investments, has just published a new supplemental disclosure for Alternative Investments. This new disclosure is very important because the additional disclosure seeks to further clarify the client’s investments objectives, and how investing in a particular AI is suitable.

The AI Disclosure must be completed fully and signed by both the investment professional and client(s.) The AI Disclosure is to be included with all initial and supplemental investments into Alternative Investments effective Monday, June 9th regardless of a client’s prior Alternative Investment experience. Paperwork received without the AI Disclosure beginning June 9th will not be considered in good order. Alternative Investments is a major regulatory concern and we appreciate, as always, your full attention and cooperation to help insure our client’s investment choices are the best choices for them.   

I’ve included a link to Forms section of The AI Disclosure is found under the Broker Dealer section. Remember our forms are password protected so you must be logged into the TFS website in order to access the form. Please feel free to contact me with questions.


Tomorrow's Financial Services, Inc.

Firms Responsibilities When Providing Customers with Consolidated Financial Reports

FINRA Reminds Firms of Responsibilities When Providing Customers with Consolidated Financial Account Reports

Executive Summary

The practice of providing customers with consolidated financial account reporting has become increasingly common in the financial services industry. In many cases, these reports offer a single document that combines information regarding most or all of the customer’s financial holdings, regardless of where those assets are held. Firms are reminded that these reports represent communications with the public by the firm; the dissemination of these reports must comply with all applicable FINRA rules as well as the federal securities laws.

As investor demand for this service has grown and as increasingly sophisticated software and data service providers have become available, firms have developed differing practices for generating these communications. If not rigorously supervised, this activity can raise a number of regulatory concerns, including the potential for communicating inaccurate, confusing or misleading information to customers, lapses in supervisory controls, and the use of these reports for fraudulent or unethical purposes.

This Notice reminds firms of their responsibilities to ensure that they comply with all applicable rules when engaging in this activity, and highlights a number of sound practices. Firms are strongly encouraged to review the overall adequacy and effectiveness of their current policies and procedures relating to their consolidated reporting. Any firm that cannot properly supervise the dissemination of consolidated reports by its registered representatives must prohibit the dissemination of those reports and take the necessary steps to ensure that its registered representatives comply with this prohibition.

General questions about this Notice should be directed to:

  • Steve Kasprzak, Associate Director & Principal Counsel, Sales Practice Policy, Member Regulation, at (646) 315-8603; or
  • Bill Hayden, Emerging Regulatory Issues, at (202) 728-8860.

For questions about communications with the public, contact Amy Sochard, Advertising Regulation, at (240) 386-4508.


Due to the inclement weather the TFS Home Office has sent our staff home early.  Email and Trades will continue to be monitored and busy will continue.  For emergency situations please contact the following Department Head, Steve Hipsher (Insurance) Cell #  1-732-912-1489 Tammy Case (Securities and Advisory) # 1-848-207-0052, Richard Widmer (Mortgage) # 1-908-705-1498 and Thomas P. Hyland # 1-732-245-0452.

Thank you for your patience and understanding.



Tomorrow's Financial Services, Inc.

FINRA Reminds Firms of Their Responsibilities Concerning IRA Rollovers

Executive Summary

FINRA is issuing this Notice to remind firms of their responsibilities when (1) recommending a rollover or transfer of assets in an employer-sponsored retirement plan to an Individual Retirement Account (IRA) or (2) marketing IRAs and associated services. Reviewing firm practices in this area will be an examination priority for FINRA in 2014.

Questions concerning this Notice should be directed to:

  • Thomas M. Selman, Executive Vice President, Regulatory Policy, at (202) 728-6977 or by email; or
  • Angela C. Goelzer, Vice President, at (202) 728-8120 or by email.

New Account Form Deadline

Just to follow-up with Jennette’s excellent post concerning Pershing forms from last week. After 12/31/13 the only edition of the new account form (NAF) that will be accepted by TFS is the 2-13 edition. All other NAF’s whether for brokerage, direct business or for account updates will be returned to the reps along with all accompanying paperwork and/or checks.

Pershing has made major changes to their NAF, and this version of the NAF is the version everyone needs to use. Previous versions are dramatically outdated and need to be discarded by representatives who are still using them.

Please feel free to contact me with any questions or concerns.


Tomorrow's Financial Services, Inc.

Signature Guarantees

Investopedia defines a signature guarantee as “a form of authentication issued by a bank or other financial institution that verifies the legitimacy of a signature and the signatory’s overall request. This type of guarantee is often used in situations where financial instruments are being transferred. In most cases, the guarantor accepts all consequences in the event that the signature is fraudulent.”

What Do You Need To Know About the TFS Guarantee Program?

—TFS will signaturee guarantee (SG) an original document for our clients or pending clients only providing this transaction is for TFS related business. Unfortunately, we cannot SG a request for a client or pending client for a third party.

—We cannot SG a fax or scan. Only original signatures can be guaranteed. Even if the vender is stating they will accept a faxed or scanned signature our bond does not permit us to make this accommodation.

—Our bond limit is $250,000 per transaction. Requests over that amount cannot be honored. For example, John Smith is transferring three accounts into his new brokerage IRA. Each of those three transfers is considered a separate event so the total dollar amount can be over $250,000. However, the combined dollar amount cannot be over $500,000 with no single transfer over $250,000.

—If a SG request is being sent to home office as part of pending business, a copy of the client’s valid driver’s license must be submitted as well. There are no exceptions. If the request is for an existing client, then a copy of the client’s driver’s license is not necessary.

—A SG request must also include Request for Signature Guarantee form. This form is required to be signed by the representative and client.

—TFS home office will not determine if a SG is necessary for a piece of business that has been received by home office. That is the responsibility of the representative and client. If you are unsure a transaction you are processing for a client requires a SG, please contact your manager, OSJ or the vender directly.

If you have any questions, feel free to contact me


It’s That Time of Year….

…to submit your year-end requirements.

Not sure what to send in?

No problem.

As discussed during last month’s annual Compliance meeting a copy of all advertising including business cards, stationary and email signatures need to be sent to your manager along with an advertising approval form before being sent to TFS Compliance for approval, so why not get this requirement out of the way before TFS Compliance starts asking for it?

If you have any questions feel free to contact me at




Important Change Regarding Change of Broker/Dealer Requests

Prudential recently changed their policy concerning change of Broker/Dealer requests. Prudential will no longer accept faxed or emailed change of Broker/Dealer requests. All requests must contain original signatures.

As of right now all of our other business partners are still accepting change B/D requests via email or fax after they have been approved. If that policy changes, TFS Complaince will notify the field promptly. Also, just a reminder, a change of Broker/Dealer request must be accompanied by a signed new account form if the client is either changing firms or representatives. A change of B/D will not be processed until a NAF is received and in good order.

If you have any questions feel free to contact me


A reminder concerning TFS Advisory Services

The end of the year is rapidly approaching and so is the exciting changeover from Innovative Market Trends to TFS Advisory Services. As a part of this changeover all representatives, managers and OSJ principals need to remember a few important items.

1) All stationary (business cards, letterhead, fax cover sheets, notepads, etc.) need to reflect TFS Advisory Services.

2) All websites and signage need to reflect this change as well.

3) Many reps utilize various services to generate client newsletters. These venders must contacted to update the change as well.

4) As of December 31, all items in your office or associated with your business must reflect TFS Advisory Services, and these changes must be submitted to your manager then Compliance with an Advertising Approval Form. Absolutely nothing with IMT will be approved and there are no exceptions.

Here is the TFS Advisory Services disclosure for your reference:

Investment Advisory Services Offered Through TFS Advisory Services, a Division of TFS Securities, Inc.


Tomorrow's Financial Services, Inc.

FINRA Rule 9217 to Include add. Rule violations Eligible for Disposition Under Minor Rule Violation

SEC Approves Amendments to FINRA Rule 9217 to Include Additional Rule Violations Eligible for Disposition under FINRA’s Minor Rule Violation Plan

Effective Date: September 26, 2013

Executive Summary

The Securities and Exchange Commission (SEC) approved amendments to FINRA Rule 9217 to include additional rules for disposition pursuant to FINRA’s Minor Rule Violation Plan (MRVP). The additional rules are set forth in Attachment A. The amendment became effective September 26, 2013.

The text of the amended rules is available at

Questions concerning this Notice should be directed to Philip Shaikun, Associate Vice President and Associate General Counsel, Office of General Counsel, at (202) 728-8451.