Table of Contents Personal Address Change 3 49 Financial Office Addresses 4 Insurance License Address Update Instructions (via NIPR) 5 Company Appointment Address Update Instructions (via SureLC) 7

 

Personal Address Changes (to be completed within 30 days after your move!)

 

See attached guide for full instructions on all the steps you should take whenever you have personal or business address changes. Quick summary is below;

1. Email [email protected], [email protected] , and your GOC to inform all parties of your new personal address (date moved, old address, new address). 

2. fix

a. Login and go to “Information” > “Address & Contact Information”

3. Update your address on NIPR (or Sircon) (instructions attached)

4. Update your address on the following (instructions attached):

a. PKS SureLC

b. FIG SureLC

 

 

 

 

 

Client Address Change

 

If you received requests from your clients this week to make a change of address , send an email to your GOC and CC [email protected]  with the following information:

· Client name:

· Account number(s):

· Old address:

· New address:

· Date received:

· Date processed:

· Indicate if this is a Broker Dealer Client, RIA Client etc

 

Also, make sure to update their address with all the respective carriers in which they have business.

 

 

Thank you so much!

 

 

 

 

 

 

 

 

 

 

ADDRESS UPDATE INSTRUCTIONS

 

 

Please complete all the following steps to update your personal or business address when a move has occurred.

 

*Be advised, these instructions are for address changes within your resident state only. If you have moved states, please reach out to [email protected] for additional information.

 

 

Personal Address Change

 

1. Email [email protected] (cc [email protected] and your GOC) indicating the date you moved, your old address, and your new address.

2. Update address in Paycom.

a. Login and go to “Information” à “Address & Contact Information”

3. Update your address on NIPR (or Sircon). Instructions below.

4. Update your address on the following (instructions below):

a. PKS SureLC

b. FIG SureLC

 

 

Business Address Change

 

Follow steps 3 & 4 above, only.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Financial Office Addresses

· Austin (HQ):

· 916 S Capital of Texas Hwy Suite. 2.100 Austin, TX 78746 o (512) 387-0495

· Arkansas:

· 5001 W Founders Way Suite 100, Rogers, AR 72758 o (479) 531-3591

· Atlanta:

· 3101 Cobb Pkwy SE Suite 124, Atlanta, GA 30339 o (404) 919-6710

· Charlotte:

· 1213 W Morehead St. Suite 508, Charlotte, NC 28208 o (704) 412-1868

· Dallas:

· 14555 Dallas Pkwy Suite 100-212 Dallas, TX 75254 o (214) 494-0175

· Houston:

· 1334 Brittmoore RD Suite 2610 Houston, TX 77043 o (832) 301-9308

· Jacksonville:

· 13475 Atlantic Blvd. Unit 8, Suite M779 Jacksonville, FL 32225 o (904) 351-6352

· Los Angeles:

· 3500 N Sepulveda Blvd, Suite E, Manhattan Beach, CA 90266 o (310) 494-6919

 

 

 

 

 

 

 

 

 

 

 

Insurance License Address Update Instructions (via NIPR)

 

Go to NIPR.com and select “Apply for New License”

 

 

 

Then click “Go to the Online Application”

 

 

 

Login to the Individual License portal with your SSN, Last Name, and Birthdate and from the

Menu, click “Start” and select “Contact Change Request”

 

 

 

Select Physical Addresses. Click “Edit this address” and update to your new personal address or new branch office address. Then select “Move all states to this address” to update all states.

 

Company Appointment Address Update Instructions (via SureLC)

 

Login to your PKS portal and open SureLC. Under the “MyProfile” section click “edit” under the address information section to update your personal or business address.

 

 

Repeat this step for FIG by logging into your FIG Marketing portal and going to the contracting section and clicking “New Contract Request” to open the FIG SureLC portal.

 

Gifts – Policy & Procedures 

 

Giving and receiving rule 

· $100 limit per year per person (no cash)

· Husband and wife who are both clients can have $200 in gifts towards their household for the year

Important Details 

· 49 Financial merchandise / branded items:

· DO NOT need to be reported and do not count towards the $100 limit!

· As long as the item is not something extravagant, therefore, only items from the merchandise store are appropriate and nothing should have 49 Financial branding added without approval from marketing and compliance.

· Perishables:

· DO count toward $100 limit, unless it is a homemade item. Anything bought from a vendor would count towards the gift limit

· Examples

· Wine, charcuterie, cheeses, various finer things are limited to $100 per person

· Homemade cookies do not count

· Entertainment:

· If you attend an entertainment event with a client where you cover the costs it can be considered a business expense and not necessarily a gift.

· This cannot be something done on a regular basis with the same client.

· If you do not attend with the client, that counts towards the gifting limitations

· Examples

· Golf Round

· You purchase a round of golf and play with your client(s) – no reporting necessary and no $100 limit

· You purchase a round of golf for your client to play on their own – This is a reportable gift and must be within the $100 limit

· This could be considered excessive if you did this monthly with the same client and/or the expenses could be considered extravagant.

· Sporting event / concert / festival etc..

· You buy tickets and attend a Houston Astros game with a client – no reporting necessary and no $100 limit

· You buy tickets and don’t attend a Houston Astros game with a client – This is a reportable gift and must be within the $100 limit

· This could be considered excessive if you did this monthly with the same client and/or the expenses could be considered extravagant.

· Ex. Thousands of dollars spent for behind the dugout seats for game 6 of the World Series in 2022 when the ‘Stros closed out the Phillies.

· Client Events:

· If you host and attend client appreciation events, you do not have to report this as a gift

· This cannot be something done on a regular basis with the same client.

· Example

· Annual appreciation dinner with client(s) that you also attend

· DO NOT need to report and isn’t restricted to $100 gifting rules.

· Monthly wine tour of Napa Valley with luxury hotel and food accommodations

· Could be considered extravagant and would NOT be a reasonable expense / gift.

 

Reporting requirements  

· You must maintain and update a PKS Gift Log saved in your personal Sharepoint using the gift log spreadsheet.

· Reps are required to self-track prior to 2022.

· 2022 and beyond, in addition to tracking on your own, we require advisors to report ALL gifts (sent and received) to compliance@49Finanicial.

· Send an email to compliance@49Finanicial with all the details of the gift that are included in the spreadsheet tracker

 

Consequences 

· Compliance findings on your record

· Fines

· Could lead to firings if egregious

· Consistent violations could result in being barred from the industry

OBA, OPA and OPI

 

OBA (Outside Business Activity) 

· Outside Business Activities means any activities that a Supervised Person may be engaged in outside of their employment with 49, including, but not limited to, service as an officer, director, partner, employee, consultant, or independent contractor with any for-profit or non-profit organization.

· AKA you are a decision-maker with influence on an organization and/or anything that earns you income outside of this job.

· If you have an undisclosed OBA, a change to an existing OBA, or plan to engage in an OBA, please fill out the PKS OBA (attached) and email it to  [email protected]  with your GOC cc’d for review before forwarding to  [email protected]  after internal approval.

 

OPA (Outside Personal Account) 

· An Outside Personal Account is any investment account that is held away from our RIA for you or anyone residing in your household.

· For example, this could be a Robinhood account, retail Fidelity/Schwab account where no IMA was signed and submitted, a spouse’s E-trade account etc…

· If you have any undisclosed investment accounts or changes to previously disclosed accounts, please fill out the PKS OPA form (attached) and email it to  [email protected]  with your GOC cc’d before forwarding to  [email protected]  after internal approval.

 

OPI (Outside Passive Investment) 

· An outside passive investment is essentially a private investment into something that cannot be traded through PKS.

· Ex. Private placement, limited partnership, non-public company etc…

· If you have any undisclosed passive investment accounts or changes to previously disclosed accounts, please fill out the PKS OPI form (attached) and email it to  [email protected]  with your GOC cc’d before forwarding to  [email protected]  after internal approval.

 

Not updating these items prior to engaging in an OBA or disclosing in a timely manner the opening of a new investment account could result in compliance findings and issues maintaining those OBA’s/OPA’s.

 

OBA (Outside Business Activity)

· Outside Business Activities means any activities that a Supervised Person may be engaged in outside of their employment with 49, including, but not limited to, service as an officer, director, partner, employee, consultant, or independent contractor with any for profit or non-profit organization.

· AKA you are a decision maker with influence on an organization and/or anything that earns you income outside of this job.

· If you have an undisclosed OBA, a change to an existing OBA, or plan to engage in an OBA, please fill out the PKS OBA (attached) and email it to  [email protected]  with your GOC cc’d for review before forwarding to  [email protected]  after internal approval.

 

OPA (Outside Personal Account)

· An Outside Personal Account is any investment account that is held for you or anyone residing in your household.

· For example, this could be a Robinhood account, retail Fidelity/Schwab account where no IMA was signed and submitted, a spouse’s E-trade account etc…

· If you have any undisclosed investment accounts or changes to previously disclosed accounts, please fill out the PKS OPA form (attached) and email it to  [email protected]  with your GOC cc’d before forwarding to  [email protected]  after internal approval.

 

· An outside passive investment is essentially a private investment into something that cannot be traded through PKS.

· Ex. Private placement, limited partnership, non-public company etc…

· If you have any undisclosed passive investment accounts or changes to previously disclosed accounts, please fill out the PKS OPI form (attached) and email it to  [email protected] with your GOC cc’d before forwarding to  [email protected] after internal approval.

 

Not updating these items prior to engaging in an OBA or disclosing in a timely manner the opening of a new investment account could result in compliance findings and issues maintaining those OBA’s/OPA’s.

 

 

If you have any questions/concerns, please feel free to reach out!

 

Thank you!

 

Receiving Client Checks/Securities Policy

 

 

If you received custody of client checks this week ,  MAKE A COPY OF IT  and send an email to  [email protected] (cc GOC) with the copy and the following information:

· Date Received:

· Client Name:

· Check Number:

· Payable to:

· Check Amount:

· Date Sent:

· Sent to:

· Sent by:

· Shipping method:

 

If you received custody of client securities this week ,  MAKE A COPY OF IT  and send an email to  [email protected] (cc GOC) with the copy and the following information: (extremely rare)

· Client name:

· Client address:

· Client telephone number:

· Settlement date:

· Delivery date:

· Receiving party’s name:

· Quantity:

· CUSIP number:

 

 

Feel free to reach out to [email protected] with any questions.

Communicating With Clients​

 

Best Practices​

 

· Use your 49 Financial e-mail address when talking to clients about securities-related matters. Do not use personal email accounts.​

· Don’t use text messages to discuss investment strategies, specific securities, or any sensitive information with clients.​

· When making changes to accounts, it is best to call and e-mail the customer. ​

· ​

· Keep all records of communication with clients! ​(This protects you in case of something going astray)​

 

I.R.L Example​

FINRA Disciplinary Action​

 

· FINRA fined William Bryson Baum $5,000 and suspended him from association with any FINRA member for 30 days. ​

· He sent 58 text messages relating to his securities business, including investment strategies and specific securities, to 16 customers over a year.

 

IDENTITY THEFT

 

 

RED FLAG​

 

· When an account is used in a manner that is not consistent with established patterns of activity on the account. ​

 

For example, look out for:​

 

· An increase in the use of available credit or margin; ​

· A material change in deposit or withdrawal patterns; or​

· A change in electronic fund transfer patterns in connection with the account. ​

· Mail sent to the customer that is returned but transactions continue to be conducted in connection with the client’s account. ​

 

PREVENTING & MITIGATING ​

IDENTITY THEFT​

 

Steps to take if you believe a client account might be compromised:

 

 

 

 

Contact the client

 

· Monitor covered accounts for evidence of identity theft.​

· Assist client in changing any passwords, security codes, or other security devices that permit access to a covered account or sensitive information.​

· Work with custodians to reopen a covered account with a new account number or close an existing covered account at client’s request.​

· Contact and work with law enforcement if necessary.​

 

 

 

 

 

Non-Public Information

 

Corporate news or information that has not yet been made public and which could also have an impact on its share price.​

Under insider trading laws, a person or company that illegally trades in securities of a company while in possession of material, nonpublic information about that company may be subject to severe sanctions, including civil penalties, fines, and imprisonment.

 

 

I.R.L Example

 

In September 2017, financial analyst Brett Kennedy was charged with insider trading and sentenced to 6 months in prison.​

Kennedy gave a friend information on Amazon’s 2015 first-quarter earnings. The SEC said Rezakhani made $115,997 trading Amazon shares based on the tip from Kennedy.

 

 

What You Should Do​

 

ALL Registered Individuals must report all business, financial or personal relationships that may result in access to material, nonpublic information to the Compliance department.​

 

 

 

PKS Communications Practices

 

Email Communications ​

 

Emails are an approved form of communication and every email communication from a Registered Representative much contain a disclosure that securities are offered through PKS. ​

 

PKS Disclosure (Non IAR) Email

 

Securities offered through Purshe Kaplan Sterling Investments, Member FINRA/SIPC Headquartered at 80 State Street, Albany, NY 12207. Purshe Kaplan Sterling Investments and Thrivent Advisor Network are not affiliated companies​

 

PKS Disclosure (IAR) Email

 

Securities offered through Purshe Kaplan Sterling Investments, Member FINRA/SIPC. Headquartered at  80 State Street, Albany, NY 12207.

49 Financial often communicates with its clients and prospective clients through electronic mail (“email”) and other electronic means. Your privacy and security are very important to us. We make every effort to ensure that email communications do not contain sensitive information. We remind our clients and others not to send us private information over email. If you have sensitive data to deliver, we can provide secure means for such delivery. Please note: 49 Financial does not accept trading or money movement instructions via email. As an Investment Adviser Representative, our emails may be subject to inspection by the Chief Compliance Officer (“CCO”) of the Thrivent Advisor Network or the securities regulators. If you have received an email from us in error, we ask that you contact the sender and destroy the email and its contents. Advisory Persons of Thrivent provide advisory services under a practice name or “doing business as” name or may have their own legal business entities. However, advisory services are engaged exclusively through Thrivent Advisor Network, LLC, a registered investment adviser.  49 Financial and Thrivent Advisor Network, LLC are not affiliated companies.

 

 

Text Messages​

 

Using text messages as a form of communications with clients about account related matters is prohibited! ​

 

 

 

Phone Calls​

Phone calls with clients are an approved form of communication concerning account related matters.​