Office File Requirements

RETAIL CLIENT FILES: Must be kept for 6 years after the account is closed

1. New account form that has been updated at least every 36 months
2. Copies of all applications and checks taken
3. Copies of all materials presented to the client
4. Notes detailing all personal visits and phone conversations with the client
5. Copies of all correspondence to or from the client
6. Confirmations on all transactions
7. Quarterly and annual statements

WHOLESALE CLIENT FILES: must be kept for 6 years after the account is closed, or policy replaced

1. New account form
2. Copy of application
3. Copy of illustration (with client initials if required by your state)
4. Copy of policy receipt

OFFICE REQUIREMENTS: all files must be kept, even if empty – all except personnel file must be kept at least 3 years

1. Advertising file
2. Customer complaint file
3. Correspondence file
4. Personnel file with fingerprints and copy of U-4, CE records – must be kept indefinitely
5. Transaction blotter including check numbers
6. Any office personnel that handle applications or checks must be fingerprinted
7. All securities related email must be archived through our service provider (Smarsh) and contain the securities disclaimer (Securities offered through Simplicity Investments Member FINRA/SIPC)
8. Internet access to Compliance Manual and FINRA manual