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Client Identification Program (CIP) Uplift Overview

Earlier this year, we alerted all advisors using our platform of additional compliance information that we require from all clients, trusts and entities. Providing this information will bring 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.

When do the new CIP requirements apply?

We understand that in many instances, gathering the required information from your existing clients has been and or will be quite time consuming, so we have extended the time to update this information until August 5th, 2022. It is imperative that you complete these updates within this time period. Accounts not updated during the time provided will be subject to “Sell-Only” restrictions that will remain in place until the required information is provided, and in some cases reviewed and approved. 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.

What are the new CIP requirements for existing clients?

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.

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.

Trust Accounts

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.

Entity Accounts

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.

What are the new CIP requirements for new clients?

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:

  • Middle name instead of middle initial.
  • Country(s) of citizenship instead of U.S. or Permanent Resident.
  • Is the client a Politically Exposed Person (PEP)? (definition provided on our site and forms)
  • Expected activity with checks, wires and certain high risk securities.

How do I provide the new CIP required information?

For Clients:

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 support@folioinstitutional.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) 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 “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 support@folioinstitutional.com 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.

Will clients be notified of the CIP changes?

To provide you with additional support, starting in July, any client who logs into our website ⚋ and has not provided the required source of wealth information ⚋ will see an “Item for Attention” that they must complete before they can view their account.

How can I see which clients still need CIP updates?

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:

  1. Requires Update — if we are missing any information, such as the source of wealth for a client and or the Trust Information and Trust Parties for each trust account under a client, trust account legal evidence of existence documentation, etc.
  2. Updated — if all CIP data has been entered, trust account legal evidence of existence documentation provided through the Secure Upload link on the Advisor site and all required documentation for entities, QRPs and certain trusts has been provided, reviewed and approved.
  3. Not Applicable — for clients with no funded accounts, only accounts with less than $1, and or only closed accounts.
  4. Requires Trust Doc — if source of wealth for a client, all trust parties and all other trust account information has been provided but legal evidence of existence documentation for the trust has not been provided through the Secure Upload link on the Advisor site.
  5. Requires Entity Questionnaire — if we have not yet received the Entity Questionnaire and required supplemental documentation, and reviewed and approved an entity account (not QRPs) or a Statutory Trust or a trust with non-natural person trust parties (e.g., a trust is a beneficiary or grantor of the trust), which may take several days, or longer if there are follow-up questions or a large number of submissions at the same time.
  6. Requires QRP form — if we have not yet received the QRP Form and required supplemental documentation, and reviewed and approved the QRP account, which may take several days, or longer if there are follow-up questions or a large number of submissions at the same time. Note that one form with a list of participant sub-accounts may be submitted for each plan, instead of one form for each participant sub-account.
  7. Requires Trust and Entity docs — if all other trust account information has been provided for a business trust but legal evidence of existence documentation for the trust has not been uploaded and the trust is a Statutory Trust and or has non-natural person trust parties (e.g., a trust is a beneficiary or grantor of the trust) and we have not yet received the Entity Questionnaire and required supplemental documentation, and reviewed and approved the account.

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.

What else might I need to do for CIP changes?

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.

What if a client forgets his username?

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:

  1. Go to the client login screen
  2. Next to the Username field, select Forgot Username
  3. Verify personal information
  4. We will then email the username to the client email address that we have on record

What if a client forgets his password?

If their password is not locked, advise your client to reset their password directly from the Folio Client Login page by doing the following:

  1. From the Login page, select “Reset Password?
  2. Enter the username and select Continue.
  3. Verify the email address shown and select Reset Password? which will send a link to that email address, or contact Customer Service.

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.

How do I change or update a client’s personal or employment information?

To change or update a client’s personal or employment information:

  1. Go to the Client Accounts page
  2. Under More Info select View Client Settings
  3. Next to Client’s Information or Employment Information select Edit
  4. Change or update the information, then select Continue
  5. Select Yes to confirm the changes

For security reasons, you must mail, email or fax to us the documents listed below to change a client’s name, birth date, social security number or tax id number.

  • Name: To change the name on your client’s account, send us a letter explaining the reason for the change, along with a copy of a marriage certificate, divorce decree or other applicable court order.
  • Date of Birth: To correct your client’s date of birth, send us a copy of his birth certificate.
  • Social Security or Tax ID Number: To correct your client’s Social Security or Tax ID Number, send us a letter explaining the reason for the change, along with a completed IRS Form W-9.

Can I change a client’s username?

No. Once set, you cannot change a client’s username.

How do I change a client’s account and Folio settings?

To change or update client account or Folio settings:

  1. Go to the Client Accounts page
  2. Under More Info select View Client Settings
  3. Scroll down to the Information about Client Accounts section
  4. Under the Account Name or Folio Name, select the setting that you would like to change
  5. Follow the detailed instructions provided for each of the settings

How do I close a client’s account?

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:

  1. Go to the Client Accounts page
  2. Under More Info select View Client Settings
  3. Scroll down to the Information about Client Accounts section
  4. Under the Account Name select Close Account
  5. Select Continue to close the account

Please Contact Us to close a client’s account that has already been funded.

How do I change a client’s dividend reinvestment settings?

To change a client’s dividend reinvestment setting:

  1. Go to the Client Accounts page
  2. Under More Info select View Client Settings
  3. Scroll down to the Information about Client Accounts section
  4. Under the Folio Name, select Distribution Investment
  5. Decide the new Distribution Preference, then select Continue
  6. Select Yes to confirm the change

How can I see my client’s pricing plan?

To view your client’s pricing plan:

  1. Go to the Client Accounts page
  2. Under More Info select View Client Settings
  3. Under Pricing Plans select the plan name

How can I change my client’s pricing plan?

To change your client’s pricing plan:

  1. Go to the Client Accounts page
  2. Under More Info select View Client Settings
  3. Under Pricing Plans, next to Change, select Pricing Plan
  4. Decide the new pricing plan, and select Continue

Are there other account or service fees?

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.

What are Trading Service Fees?

Trading Service Fee is a fee to offset regulatory, transaction, and processing costs imposed on broker-dealers relating to sell transactions in certain securities. The fee includes the FINRA Trading Activity Fee (TAF) and other fees that may be charged from time to time by FINRA and other self-regulatory organizations (SROs) to recover the fee they pay to the U.S. Securities and Exchange Commission (SEC) pursuant to Section 31 of the Securities Exchange Act of 1934, referred to as the Regulatory Transaction Fee (RTF). These fees are charged by the SROs to recover their costs (as well as those of the government, including the SEC) relating to supervising and regulating the securities markets and securities professionals.

Trading Service Fees are calculated as: TAF + RTF (rounded to the nearest penny).

TAF = $0.000119 * shares sold in each trade or $5.95, whichever amount is less.

RTF = the principal amount * 0.00002310

Example:

If you sold 200 shares of a security for $5,000.00, the Trading Service Fees would be equal to $0.14.

$0.14 = [(0.000119*200) + (0.00002310*$5,000.00)]

How do I grant client account access to other people?

Only current clients may be given access to other accounts:

  1. Go to your Client Accounts page
  2. In the Account Options menu, select Account Access
  3. Select Grant Access
  4. Select the account, enter the person’s username and birth date, then select an access level
  5. After entering the above information, select Grant Access
  6. Decide the access level for viewing Account Documents and Email Messages, then select Grant Access
  7. Review the Agreement to Grant Access, and then select Grant Access to complete the process.

How can I modify others’ access level on my client’s accounts?

You can modify others’ access level on client’s accounts but cannot change the Account Creator’s access level:

  1. Go to your Client Accounts page
  2. In the Account Options menu, select Account Access
  3. Under Modify Access select the Change Icon
  4. Choose the new access level, then select Change Access
  5. Decide the access level for viewing Account Documents and Email Messages, and then select Change Access to complete the process.

What are the levels of account access?

There are six levels of account access:

Account Summary Viewer

Account Summary Viewers can:

  • View account summary
  • View account holdings
  • View account performance
  • View account statistics
  • View Folio summary
  • View Folio holdings
  • View Folio performance
  • View Folio statistics

The Account Summary Viewer cannot conduct any activity on the account.

Examples:

An investment advisor with Account Manager access might provide Account Summary Viewer access to a staff person who needs account balance information to maintain the advisor’s records.

A person might grant Account Summary Viewer access to his or her spouse.

Account Detail Viewer

Account Detail Viewers can:

  • View account order status
  • View tax information
  • View Folio transaction history
  • View Folio holdings
  • View Folio order status
  • View Folio tax information
  • View Profile page
  • Do anything that can be done by Account Summary Viewers

The Account Detail Viewer cannot conduct any activity on the account.

Examples:

An investment club might grant its member Account Detail Viewer access.

The custodian of an UGMA/UTMA account might grant Account Detail Viewer access to the account beneficiary.

Money Mover

A Money Mover can:

  • Deposit and withdraw money
  • Create, modify and delete an EFT link
  • Set up check writing
  • Create, modify and delete auto buy/sell instructions
  • View Profile page
  • Do anything that can be done by Account Detail Viewers and Account Summary Viewers
Examples:

An investment advisor with Account Manager access might provide Money Mover access to a staff person to fund client accounts.

An investment club might grant the club’s treasurer Money Mover access to fund the account.

Trader

A Trader can:

  • Add new securities to a Folio
  • Sell Folio securities
  • Sell all Folio securities
  • Buy and sell security through direct trades
  • Modify and cancel orders
  • Create, rename, and close Folios
  • Change cash distribution (dividends, capital gains and return of capital) preference
  • View trade confirmations
  • View Profile page
  • Do anything that can be done by Money Movers, Account Detail Viewers and Account Summary Viewers
Examples:

An investment advisor with Account Manager access might provide Trader access to a staff person who can buy and sell securities in client accounts.

An investment club might appoint specific individuals to trade on the club’s behalf.

Account Manager

The Account Manager is the highest access level that can be granted. An Account Manager can:

  • Grant, change and delete access
  • Vote proxy statements and corporate actions
  • View account statements
  • View restricted account alerts
  • View corporate action alerts
  • View change IRA beneficiary alerts
  • View order cancellation alerts
  • View EFT alerts
  • View and change Profile page
  • Modify account settings—account name, change order limit, security exclusions, tax lots, fund for cash, and IRA beneficiaries
  • Close accounts for which there hasn’t been any trading or funding activity
  • Do anything that can be done by Traders, Money Movers, Account Detail Viewers and Account Summary Viewers

An Account Manager cannot close the account or change your password.

Examples:

You might provide access to your investment advisor so he or she can manage your account.

You might provide access to your spouse so he or she can manage the account (even if he or she doesn’t own it).

Account Creator/Owner

Account Creator or Account Owner is the highest level of access. This level is established when the account is opened.

The only difference between Account Creator and Account Owner is that the Account Creator is the owner of the account and opened the account. This distinction is for record-keeping purposes only.

The Account Creator or Account Owner can:

  • Grant, change and delete access
  • Vote proxy statements and corporate actions
  • View account statements
  • View restricted account alerts
  • View corporate action alerts
  • View change IRA beneficiary alerts
  • View order cancellation alerts
  • View EFT alerts
  • View and change Profile page
  • Do anything that can be done by Account Managers, Traders, Money Movers, Account Detail Viewers and Account Summary Viewers
Examples:

Someone who opens an individual account (Account Creator).

You open a joint account with your spouse. Since you opened the account, you are the Account Creator. Your spouse is an Account Owner.

Does my client have account protection?

Through Folio Investments, Inc., we are a member of the Securities Investor Protection Corporation (SIPC) which protects the securities of its members’ customers up to $500,000 for each customer (including $100,000 on claims for cash). SIPC covers against losses stemming from a member broker-dealer’s financial failure. A brochure explaining the coverage provided by SIPC is available on its website at www.sipc.org. In addition to SIPC coverage, we have also purchased from certain underwriters at Lloyd’s, supplemental customer securities insurance with a total aggregate limit of $50 million. This coverage is limited to a combined return of $10 million to any customer from SIPC and certain underwriters at Lloyd’s. Neither SIPC coverage nor supplemental insurance protect against losses resulting from a decline in the market value of securities.

Cash deposits are insured by the Federal Deposit Insurance Corporation (FDIC), an independent agency created by the U.S. Congress in 1933 to help maintain public confidence in the nation’s financial system. One of its primary duties is to insure deposits in banks and thrift institutions. If you would like more information about FDIC insurance, please visit www.fdic.gov or call the FDIC Consumer Hotline at 1-877-ASK-FDIC (1-877-275-3342).

For more information on SIPC and FDIC Coverage, please see our custodial brochure.

How is my clients’ and my personal and financial information protected?

Please read our privacy and security statement to learn how we protect and use you and your clients’ personal and financial information.

We maintain physical, electronic, and procedural safeguards in keeping with securities industry standards and practices that are designed to protect your personal and financial information. We review and adjust these safeguards as necessary in response to security best practices. Your account information will be placed on a secure portion of our Web site. You must log in under your unique username and password to view your financial data. Anytime you exit our site, we recommend using the “LOG OUT” button.

We protect the transmission of information from your computer to ours through encryption. You cannot gain access to our site unless you are using an up-to-date browser with a minimum of 128 bit encryption. View our Minimum Browser Compatibility Requirements.