Early in 2022, we alerted all advisors using our platform of additional compliance information that we require from all clients, trusts and entities. Providing this information brings your client data up-to-date with the ever-evolving industry standard requirements, and in line with the Goldman Sachs client onboarding and maintenance requirements. By understanding your client's source of wealth and related client information, we'll be better equipped to meet regulatory and compliance requirements.
It is imperative that you complete these updates right away for any clients or accounts that have not already been updated. Accounts not updated have been subjected to “Sell-Only” restrictions that will remain in place until the required information is provided, and in some cases reviewed and approved. A ?Sell Only? restriction still allows the sale of securities and the transfer of securities to another firm but does not allow other actions, such as buying securities or withdrawal of funds by check, wire or ACH/EFT.
Note that reviews of required documentation for entity and qualified plan accounts (e.g., LLC, Corporation, 401(k), etc.) take time, and will be delayed if most of the documents arrive near the deadline, so please send us the completed Entity Questionnaires and QRP Forms as soon as possible.
Client Source(s) of Wealth
Sources of wealth are the only new information required from most existing clients, which can be updated on each client's Account Settings page. A client's source of wealth refers to the manner in which a material portion of their wealth was derived, whether or not that wealth is held at our firm. To review the new questions before entering the information on our website, please see page 5 of our updated New Client Information form.
A source of wealth is required for each client on the platform, including clients that are secondary joint account holders, clients that are authorized representatives of business trusts and other entities, and clients that are setup to view other clients’ accounts.
Note that detailed instructions on how to provide the required information for clients and certain account types is provided below, in the “How do I provide the required updates?” FAQ.
We now require information about each trust, such as the date and country of formation, and information about all of the individuals associated with each trust (i.e., Authorized Signatories, Beneficiaries, Grantors/Settlors, Protectors and Trustees), as well as documentation that evidences the legal existence of each trust (such as a certificate of trust, declaration of trust, trust deed, or the first page and signature page(s) of the fully executed trust agreement). You can review guidance about this information on pages 12 and 13 of our updated New Client Information form and provide the required information on the Account Settings page for each client that owns a revocable trust account or is the authorized representative of a business/irrevocable trust account. In the case that a trust has another trust or entity associated with it, such as a trust as a trustee or beneficiary, we also require our new Entity Questionnaire be completed.
We require the new Entity Questionnaire to be completed for all accounts owned by entities (e.g., Corporations, LLCs, Partnerships, etc.,) in which we collect information such as ownership structure and documentation that evidences the legal existence of the entity. Consistent with our current process, we will review the information provided, and may require additional information, prior to granting full access to a new entity account or removing a restriction on an existing account.
Qualified Retirement Plan (QRP) Accounts
For each 401(k) plan or other qualified plan (QRP) entity (not for each QRP participant sub-account), please send us the completed and signed new QRP form and all required supporting documentation noted on the form. Consistent with our current process, we will review the information provided, and may require additional information.
All of the requirements noted above for existing clients apply to new clients, as well as the following additional items, all of which appear on our website and New Client Information form:
To enter sources of wealth for a client, select the Account Settings link next to each account on the Advisor Home Page, or select the desired Client ID/username on the Advisor Dashboard, Clients: All report, and you will be taken to the Settings page for a client. Once there, you can enter the material source(s) of wealth for a client by selecting Edit in the Additional Compliance Information box that is partway down the screen, and selecting the client’s source(s) of wealth.
For Trust Accounts:
To enter required trust information, select the Trust Information link that appears for each trust account in the Client Accounts section of the Settings page and answer the questions on the page. Then select the Trust Parties link on the Settings page to enter Authorized Signatories, Beneficiaries, Grantors/Settlors, Protectors and Trustees, all of which are required for trust accounts
To provide the documentation that evidences the legal existence of each trust (such as a certificate of trust, declaration of trust, trust deed, or the first page and signature page(s) of a fully executed trust agreement), select the Secure Upload link next to each client account on the Advisor Home Page, select the “Trust Evidence of Existence Doc” document type and upload the applicable trust document per the instructions on the page (e.g., PDF file under 10 MB).
Please only provide this trust documentation to us through this channel, as other channels will not lift the document restriction on new trusts or keep existing trusts from being restricted for missing documentation.
For Entity Accounts:
For accounts owned by entities (e.g., Corporations, LLCs, Partnerships, etc.) please complete the new Entity Questionnaire and supply all required supporting documentation noted on the form, select the Secure Upload link that is next to each client account on the Advisor Home Page, select the “Entity Client Onboarding Supplemental Questionnaire” document type and upload the document per the instructions on the page (e.g., one PDF file under 10 MB). If you need to send multiple separate files, you may email them to us at email@example.com noting the reason for the email and the account number in the subject line (e.g., Entity Questionnaire for Account 12345678). Consistent with our current process, we will review the information provided, and may require additional information.
For Qualified Retirement Plan (QRP) Accounts:
For accounts owned by qualified plan entities (e.g., 401(k), 403(b), etc.) please complete the new QRP form for each plan (not for each participant sub-account), supply all required supporting documentation noted on the form, provide a list of all participant account numbers under the plan, select the Secure Upload link that is next to each client account on the Advisor Home Page, select the “QRP Setup Form” document type and upload the document per the instructions on the page (e.g., one PDF file under 10 MB). If you need to send multiple separate PDF files, you may email them to us at firstname.lastname@example.org noting the reason for the email and the account number in the subject line (e.g., QRP form for Account 12345678). Consistent with our current process, we will review the information provided, and may require additional information.
We provide an easy-to-use report that shows which clients have been updated and which ones still need more information. Just take a look at the CIP Status column on the Clients: All report on the Advisor Dashboard.
For each Client ID, we currently show the following CIP statuses:
Note that we also added Branch and Rep code columns to this report so that you can sort using this data. You can also download the data in every Advisor Dashboard report, if you would like to filter and parse it.
In addition to updating all of your clients and their trust, entity and qualified plan accounts, we ask that you update any procedures, documents, forms, email templates, websites or other materials that your firm has created that references the information required for clients and accounts on our platform.
You can find your client’s username on the Client’s Settings page, or on your Client Accounts page under the Username category. Clients can also request their username from the client login screen by selecting the
If their password is not locked, advise your client to reset their password directly from the Client Login page by selecting the
Alternatively, you can send the Reset Password link to the client’s primary email address on file from the Client Settings page by clicking on Reset Client Password.
Update a client’s personal or employment information on the
To change a client’s name, birth date, social security number or tax ID number, send us the documents listed below:
No. Once set, you cannot change a client’s username.
Update client account settings on the Settings page for that client.
You can close a client’s account online only if it has never held any cash or securities, or submitted a transfer request. To close a client’s account online, select Close Account under the chosen Account Name on the client Settings page.
Please contact us to close a client’s account that has already been funded.
You may choose to have cash distributions (such as dividends and return of capital) at or above specific thresholds (currently $1 or more for equities and the minimum investment amount for mutual funds) automatically reinvested in the securities that paid them, if those securities are available in fractional shares. Generally, a buy order representing the cash to be reinvested is created and executed in our Window Trading process the day following the cash distribution, and the price of the purchase is determined on the basis of the price we obtain from the market center to which we route the order for execution. Cash distributions that are less than the specified threshold, and cash not reinvested, will generally be swept into the then current cash investment choice in accordance with the terms and conditions of the Insured Bank Deposit Sweep Program (defined in Exhibit 2 of the Customer Agreement) in effect at the time.
There is no charge for participating in the dividend reinvestment program and there are no additional transaction fees on transactions executed pursuant to automatic dividend reinvestments. We may change the threshold and frequency for automatic reinvestments of distributions and the securities for which this service is available at any time and from time to time without notice. You can select or change reinvestment preferences the client Settings page.Instead of sending a trade confirmation each time a dividend is reinvested, we will provide the details of those purchases on monthly account statements. This disclosure will include transaction details and information that would otherwise be included in a separate trade confirmation. In the event you would like to receive transaction details or information at an earlier date, you will be able to view such details online the business day following the date of the reinvestment or by contacting us.
There are two levels of dividend reinvestment on our system: account level and sub-account level.
If your firm is setup for sub-account level dividend reinvestment, then the reinvestment setting will be at the sub-account level and that setting will apply to all of the securities in the sub-account. The default dividend reinvestment setting for sub-accounts will be to not reinvest dividends, so if you desire to have dividends reinvested in a sub-account, you must select that on the client Settings page for each sub-account. Note that you cannot specify dividend reinvestment settings for specific securities with sub-account level dividend reinvestment.
If your firm is setup for account level dividend reinvestment (which is currently only available to a small number of firms), then the reinvestment setting will be at the account level and that setting will apply to all securities in an account, unless a security specific override is entered for an account position on the Holdings page. When your firm is setup, you will choose the default dividend reinvestment setting for accounts (i.e., reinvest dividends or not) and this can be changed for each account on the client Settings page.
If you would like to change the type of dividend reinvestment that is setup for your firm from sub-account level to account level, please contact us. Note that you cannot change from account level to sub-account level dividend reinvestment, even if you just made the change.
View your client’s pricing plan on the client’s Settings page, and make changes by selecting the Change link.
Service fees may apply for certain account activities that fall outside of routine client account management functions and are listed in our Special Service Fees.
Note that you can only change between pricing plans that are already setup on the system. Contact us if you would like to setup a new pricing plan, or adjust the terms of an existing pricing plan on the system.
Only current clients may be given access to other accounts:
You can modify others’ access level on client’s accounts but cannot change the Account Creator’s access level:
There are several levels of account access:
Account Summary Viewers can:
The Account Summary Viewer cannot conduct any activity on the account.
An investment advisor with Account Manager access might provide Account Summary Viewer access to other advisory firm employees who need account balance information to maintain the advisor’s records.
An investment advisor might grant Account Summary Viewer access to a client’s family member.
Account Detail Viewers can:
The Account Detail Viewer cannot conduct any activity on the account.
An investment advisor would generally grant their clients Account Detail Viewer account access, so that clients can monitor their accounts.
An investment advisor might grant Account Detail Viewer access to the beneficiary of an UTMA account.
Money Mover can:
An investment advisor with Account Manager access might provide Money Mover access to an employee to assist with funding client accounts.
An investment advisor with Account Manager access might provide Trader access to an employee who can buy and sell securities in client accounts.
Trader/Money Mover can:
An investment advisor with Account Manager access might provide Trader/Money Mover access to an employee who can move money into client accounts and buy and sell securities in those accounts.
The Account Manager is the highest access level that can be granted. An Account Manager can:
An investment advisor with Account Manager or Account Creator access might provide Account Manager access to an employee who is assisting with the management of client accounts.
Account Creator is the same level of access as Account Manager. This level is established for the investment advisor when they open an account.
Account Owner is a designation for the owner of an account, which enables certain features in addition to the Account Owner permissions noted above: