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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.

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.

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.

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.

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.

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.

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.

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:

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