Tag Archives: investment advisor

New Fund Changes!

Our Quarterly Fund Replacement Review has been performed. In keeping with the program’s goal of maintaining only the highest quality funds in the investment portfolio, the following changes have been implemented:exchange image 3

  • iShares North American Natural Resources (IGE) exchanged for Vanguard Materials ETF (VAW) — Due to the recent volatility in the Natural Resources asset class, it provided us with an opportunity to harvest some short-term tax losses by substituting IGE for the materially similar VAW. 
  • RS Select Growth Y (RSSYX) exchanged for iShares Mid Cap Growth (IWP) and Eagle Mid Cap Growth I (HAGIX)

The fund families currently owned in model portfolios are now: Laudus, Franklin Templeton, SunAmerica, iShares, J.P. Morgan, T. Rowe Price, Delaware, Eagle, Oppenheimer, MFS, AMG Managers, Weitz, Metropolitan, Vanguard, Western Asset, and TCW.

 For the performance of each portfolio model, or additional information on any of the extensive ongoing management benefits, please feel free to contact Tara Giarraffa Recupido at (800) 614-2980 or visit BuyHoldPlus.com.

Tomorrow's Financial Services, Inc.

Be Vigilant of Fund Transfer Request via e-mail

Hacking an e-mail account is a common thing now days. We need to be alert of Fund Transfers request via e-mail. It can inflict financial damage to the firm and the registered representative, this is something that can be avoided.

Reg. Rep. X (CRD #1234567, Registered Representative, Edison, New Jersey) was fined

$7,500 and suspended from association with any FINRA member in any capacity for 10

business days. The fine shall be due and payable on Reg. Rep. X  return to the securities industry.

The sanctions were based on findings that Reg. Rep. X falsely attested that she had confirmed

a request for a fund transfer with a customer and as a result, caused her member firm’s

books and records to be inaccurate. The findings stated that Reg. Rep. X processed the fund

transfer request that she thought a customer had sent, but the transfer request was

actually sent by an imposter who hacked into the customer’s email. In order to finalize

the transfer of funds, and to accommodate what she believed in good faith to be the

customer’s wishes, Reg. Rep. X provided a false attestation in her firm’s electronic wire transfer

system. In reliance upon Reg. Rep. X’s attestation and the information the imposter provided, the

firm wired the funds from the customer’s account to the account the imposter specified.

The imposter requested a second transfer and at that point, Reg. Rep. X and the adviser she

assisted became suspicious. Reg. Rep. X and the adviser brought the incident to a branch manager

after they determined the signature on the letter of authorization (LOA) did not match the

customer’s signature on file. As a result, the firm investigated the incident and terminated

Reg. Rep. X based on her false attestation. Reg. Rep. X initially represented that she mistakenly checked

the box attesting that she had spoken with the customer and later volunteered that she did

so knowingly.


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 tfsweb.com. 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.



Important Information about Outside Business Activities

SEC Approval and Effective Date for New Consolidated FINRA Rules (Including Outside Business Activities)

Effective Date: December 15, 2010

Executive Summary

Following the consolidation of NASD and the member regulation, enforcement and arbitration functions of NYSE Regulation into FINRA, FINRA established a process to develop a new consolidated rulebook (Consolidated FINRA Rulebook), which FINRA has discussed in previous Information Notices. FINRA is proposing new consolidated rules in phases for approval by the Securities and Exchange Commission (SEC) as part of the Consolidated FINRA Rulebook.

In August and September 2010, the SEC approved three rule filings relating to the Consolidated FINRA Rulebook. FINRA Rule 5121 (Public Offerings of Securities With Conflicts of Interest) and the FINRA Rule 11000 Series (Uniform Practice Code) will take effect on December 15, 2010. The effective date of FINRA Rule 3270 (Outside Business Activities of Registered Persons) is also December 15, 2010; however, for registered persons who are actively engaged in an outside business activity prior to December 15, 2010, firms have until June 15, 2011, to review such pre-existing activities under the standards set forth in FINRA Rule 3270, including the requirement that firms keep a record of their compliance with such standards.

Questions regarding this Notice should be directed to:

  • Kosha Dalal, Associate Vice President and Associate General Counsel, Office of General Counsel (OGC), at (202) 728-6903 (regarding the FINRA Rule 11000 Series);
  • Gary Goldsholle, Vice President and Associate General Counsel, OGC, at (202) 728-8104 (regarding FINRA Rule 3270); or
  • Stan Macel, Assistant General Counsel, OGC, at (202) 728-8056 (regarding FINRA Rule 5121).







The full-service fiduciary

Regulation is sweeping the industry worldwide and will change the way insurance agents and financial advisors conduct business in the future.

full_service-resize-380x300In 2010, the passage of the Dodd-Frank Act in the United States required a uniform fiduciary standard covering both stockbrokers and financial advisors when providing personalized financial advice. Recently, the Australian legislature imposed a fiduciary duty to act in customers’ best interest applying to all retail products, including superannuation and investment products. In the Netherlands and U.K., they are banning commissions and moving to a fee-for-advice model.

Registered Investment Advisors have both a suitability requirement and a fiduciary duty. They are regulated by the SEC and are normally paid through a percentage of assets under management or on an hourly basis.

Let’s take a look at the definition of a financial advisor, according to Annuity Digest:
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