A firm would not be required to file or have a principal approve prior to use a notice distributed to plan participants that is required by ERISA or DOL rules, such as a notice that merely informs the participants of investment options that will no longer be available through the plan as of a particular date, and the investment options that will replace the eliminated options.
No, these exceptions have not changed. No, provided that the content of the website version of the retail communication appears without material change from the previously filed print version.
However, if the notice also includes performance or other information that describes the investment objectives of the new investment options, or otherwise includes Business answers headline or other graphic or text Business answers promotes these new options, the firm would be required to file the notice, unless this information is required by ERISA or DOL rules.
If a firm changes the color scheme of Business answers previously filed retail communication, must the firm refile the new version of the retail communication? If a firm distributes an institutional communication to intermediaries that fall within the definition of "institutional investor" and labels the communication for use only with institutional investors, and an intermediary subsequently distributes the communication to retail investors, is the member then required to treat the communication as a retail communication?
FINRA Rule c 3 E requires a firm to file within 10 business days of first use or publication retail communications concerning any security that is registered under the Securities Act of and that is derived from or based on a single security, a basket of securities, an index, a commodity, a debt issuance or a foreign currency registered structured products.
Questions concerning principal approval of non-promotional communications see Section C.
FINRA would not regard merely changing the color scheme of a previously filed retail communication to be a material change to the communication. See Notice to Members September In most cases, no.
See " Responsive Web Design Basics. FINRA Business answers treats interactive electronic forum posts, such as social media status updates, as retail communications rather than public appearances; however, the rule specifically excludes these posts from both the principal pre-use approval requirements and the filing requirements.
However, if the communication explicitly or implicitly induces the purchase of shares of a registered investment company, we believe that the communication could be subject to the requirements of Rule and Rule 34b FINRA would consider such a notice to be a retail communication that does not make any financial or investment recommendation or otherwise promote a product or service of the member.
Is a firm required to file, or have a principal approve prior to use, a retail communication that merely explains factual information regarding an individual retirement account, qualified plan or k account? Assuming a firm adequately labels an institutional communication as being for institutional use only, the firm would not have reason to believe, absent other facts, that the communication will be distributed to retail investors.
What if a firm uses responsive Web design technology5 to deliver a retail communication in different formats depending on the device used by a customer?
Accordingly, these exceptions have not changed with respect to posts on interactive electronic forums, despite the fact that they are no longer considered public appearances for purposes of the rule.
These procedures must provide for education and training, documentation of such education and training, and surveillance and follow-up to ensure that representatives implement and adhere to the procedures. Does "internal communication" include training and educational material prepared for use with registered representatives of affiliated broker-dealers?
The SEC staff has taken the position, however, that certain interactive content posted on a real-time electronic forum i. If a Business answers merely adds its name to the reprint or adds disclosures required to make the reprint consistent with applicable regulatory standards, the firm is not required to file the reprint with FINRA pursuant to FINRA Rule c 7 I.
Unless the firm becomes aware that the intermediary has distributed the communication to retail investors, or the firm has not adequately labeled the communication, the firm will not be required to treat the communication as retail.
Accordingly, a firm would only have to file the retail communication once. In condition 5 of the Hartford Letter, Hartford represented that the presentation of Related Performance Information will disclose performance information that is net of fees and expenses of Related Accounts, or net of a model fee that is the highest fee charged to any account managed in the strategy.
For example, if a firm has previously filed a retail communication in the format that it appears on a desktop or laptop computer, and the firm is redesigning the presentation to appear on a tablet or smart phone, the firm would not have to refile the version that will appear on a tablet or smart phone.Square helps millions of sellers run their business- from secure credit card processing to point of sale solutions.
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