Tag Archives: Securities


Effective July 1, 2015 the April 2015 version of the New Account Form will be the only version of the New Account Form [NAF] that will be acceptable for new brokerage business, direct business and account updates.

Pershing has updated the NAF to comply with recent Internal Revenue Service mandates. In order for TFS to comply with these IRS mandates we must only accept the 4/15 version of the NAF.

All other versions of the New Account Form received after 7/1/15 will be returned to the representative with the accompanying paperwork and/or checks unprocessed. This is not something TFS desires; however, this new IRS mandate is something we all must comply with.

You can view the updated New Account Form on our website at www.tfsweb.com and the form will be available on LaserApp later this week.

OBA Change of Procedure

Effective immediately, Thomas P Hyland will be approving all new and updates to Outside Business Activities. Please continue to submit OBA forms through the proper channels to your manager, but keep in mind this new step may result in additional queries from TFS Compliance or Tom himself.

Representatives should also take note that this new approval process may cause delays in approvals. Representatives should use good judgment when it comes to the timeliness of OBA submissions. All Outside Business Activities must be approved prior to engaging in the OBA. Failure to fully comply with this policy will result in immediate and swift disciplinary action.

Please direct any questions regarding this new procedure to myself or your designated Compliance Liaison.


djohnson@tfsweb.com nolivo@tfsweb.com alopez@tfsweb.com

2nd Notice – Action Required: Your Migration to the New NetX360®

As communicated last week, Pershing is retiring the existing Pershing professional platform and migrating to a new and improved version of NetX360®.

We hope you have installed the new NetX360 and have explored the application. If not, you can install it by visiting netx360.com/download.  Once installed, you can access the new version of NetX360 using your existing NetX360 user ID and password.

We encourage you to begin using the new version of NetX360 as much as possible to perform your daily tasks. You can access both applications simultaneously until the end of April, 2015. After May 3rd, 2015, the previous version of NetX360 will no longer be accessible.

Pershing is hosting several training sessions to help you become proficient with the new NetX360. Please attend one of these training sessions as soon as possible. For details of NetX360 training sessions, please log on to NetX360 and click on the Resources Tab, Learning Center, Client Training Services. We encourage you to watch the Self Learning Course located on the right hand side of the screen titled “New! Transitioning to the New NetX360″. Also, please access the “e-Learning Calendar” for training sessions that are held almost daily for the New NetX360.

Please submit any questions regarding the NetX360 migration process to Jennette Fraler at jfraler@tfsweb.com. Thank you again for your support during the migration process. For more information on NetX360, you may visit pershing.com/netx360.html or pershing.com/netx360  

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.



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.


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.


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 djohnson@tfsweb.com


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.