Security
This disclosure must happen at the beginning of the call, or at the first opportunity without interrupting the client, and before caller authentication.
These disclosures must also happen at the beginning of the call or at first opportunity before caller authentication.
What is the recorded line disclosure? What is the clients name? What is Vanguard affiliation?
State the recorded line disclosure with your name and Vanguard affiliation at the beginning of every call. The recorded line disclosure is separate from call security. Procedure states clients and other callers must be notified the call is being recorded before verifying security or beginning the conversation.
For outcalls, either the client or crew member can state / verify the client’s name to clear phone security.
A client asks, “Should I go to cash?” The advisor says, “We never recommend going to cash, ever.” What is the defect risk?
An absolute or guaranteed investment recommendation. The better framing is that recommendations depend on goals, risk tolerance, time horizon, liquidity needs, and client circumstances.
Avoid using definitive language such as always, never, certain, 100%, etc.
What is allowed to be sent as an attachment in DCC?
Advisors may only send materials to clients that are approved for Personal Investor use and are still active (have not expired). Advisors may not send any internal only materials to clients.
Advisors may only send approved materials from the " Methodology Client Approved Content" page of SharePoint, material available to clients on the investor.vanguard.com, corporate.vanguard.com and Broadridge content.
Advisors are not to save documents and reuse the saved document, the approved version of each client approved document is stored on the Methodology Client Approved Content page of SharePoint, or Broadridge.
In furtherance of the client relationship, advisors may send other non-industry related attachments such as personal photos, recipes or digital greeting cards so long as it is consistent with Vanguard's Professional Conduct Policy.
Advisors may send PDF versions of articles and webpages from investor.vanguard.com and corporate.vanguard.com if there is a print option on the screen. Advisors may not use File>Print or right-click>Print to create PDF versions of screens. If a screen does not have a "printer" print option, the screen may not be sent as a PDF document, instead the advisor may only send a link to the approved Vanguard site.
**All attachments must be sent in PDF format and cannot include internal links or URLs (see below). Word, Excel, Power Point, etc. are not acceptable.
How must money market yields be quoted?
When quoting SEC yields make sure to provide the following regulatory requirements
- The SEC yield needs to be stated
- The length of time covered by the calculation needs to be stated
- SEC Yields cannot be estimated
- They are subject to change
When must emails be responded to?
Client emails must be responded to within 2 business days of receipt. Failure to respond or no reply the message will result in a defect if audited.
You hear background noise after the original client was already told the line is recorded. What must the advisor do next?
Pass the client through 3rd party authentication. Must receive permission to ask security questions, speak, transact, and interact with the 3rd party present.
Obtain verbal permission for a third party to speak and transact for the account owner.
You must receive verbal permission from the client to give information to and/or to take instructions from the third party.
Crew should confirm the permission with the client.
For example, “Do you authorize me to discuss your accounts with your spouse / accountant / father, etc., and, if necessary, take certain transaction instructions from them during this call?”
True or False: Advisors can provide advice on all assets
False. DAP Supervision of Financial Advisors Procedure states the Vanguard Cash Plus Account, inclusive of the bank sweep and underlying money market funds, is the only self-directed account that advisors may provide advice on, and advisors may not provide advice on any other self-directed account or outside account.
Advisor cannot make specific investment recommendations and do not have discretion on DAP managed accounts.
What is required to check before sending client approved material as an attachment?
Confirm the attachment is not expired and the most current version before sending. DO NOT USE CLIENT APPROVED MATERIAL PREVIOUSLY SAVED TO YOUR COMPUTER
How must crew quote exact balance information to clients? How do you quote settlement fund balance and funds available to trade?
Crew must quote the balances located on the “Current balances” tab on the Balances and holdings page. This page shows intraday balances. If a client has brokerage assets it will show the most recent price (20 minutes delayed).
When quoting a total balance for assets held at Vanguard, Crew must include the date of the pricing information for the Vanguard Mutual Funds. This information can be located by placing your cursor on the word “Price”, in the Price column.
Note: Please use the word “listed” as the “Total assets” figure may include Outside Investments.
When quoting individual balances of accounts or holdings crew must provide the most updated pricing and timing information for the investments. For brokerage assets the time and date of the pricing is located within the header of the Price column.
Vanguard Mutual Funds – “Mr. James, as of the close of business on June 6th the balance in your Dividend Growth Fund is $ 20,995.07.”
Brokerage Assets – “Mr. James, as of 12:12 pm today the balance of your Blackrock Enhanced Equity Div Trust is $45,344.53”
Advisors should document the client conversation and close out the appointment in Dynamics within this timeframe.
Within 2 business days. DAP Supervision of Financial Advisors Procedure states the conversation should be documented in Dynamics within 2 business days and advisors should close out the appointment correctly in Dynamics within 2 business days.
A third party joins the conversation. What should the advisor do next?
If a third party has joined the conversation and prior to engaging with the third party (responding to their questions, etc.), the Vanguard phone associate must introduce themselves with their full name, state the Vanguard affiliation and advise the third party that they are speaking on a recorded line. We may not assume that the third party heard the initial greeting or automated script.
What components should be covered when recommending Cash Plus?
Is the cash plus a savings account?
Does the cash plus have billpay?
The conversation must include 3 components – Client Need, Yield Consideration, Feature Alignment.
Do not call Cash Plus a “savings account.” You may instead say “savings account alternative
•Advisors CANNOT use the industry-specific term “BillPay” as Cash Plus does not offer this feature which allows clients to provide Payee or merchant information to the bank/financial institution for payments.
Advisors CAN highlight the “Bill Payment” feature of a Cash Plus account.
Advisor A is out of the office and tells their buddy, Advisor B to provide email coverage while they are out of the office. Who receives a defect if the email is not responded to?
Advisor A. If you are out of the office, the advisor is responsible for ensuring a Buddy will respond to client emails.
How and when can crew provide approximate balances?
When do tasks become overdue?
After 2 business days
Before sending a security code, the advisor must do these two things.
When can an advisor select "client does not have phone" to bypass the security code?
Inform the client that the code is being sent for call security and ask for consent to send the code.
MUST receive consent before sending the code
Security Codes are now mandatory for eligible callers if presented by the Caller Authentication window. Crew should not select "Client cannot receive a security code" option without first positioning the sending of Security Codes to the caller.
If the client states they do not have their phone, client has an international number from a country that does not allow the code, client has a landline only, Discretion may be applied in limited situations to authenticate and service the caller, such as unreasonable lengthy delay related to technical issues or difficulty with navigation with receiving Security Codes (internal or external), strong client objection (limited accommodation), or other extenuating circumstances.
If a decision is made to bypass Security Codes, the expectation should be communicated to the caller that it will be required on future calls for their account security.
How should advisors handle client questions about taxes?
We cannot give tax advice but we can provide facts, education, and guidance. Do not default to a tax profession for all scenarios, do your best to work within the scope of your role.
Ex: A client does not need to pay for a tax professional to find out what the tax brackets are. This is a fact we can provide or guide clients to where to find it online
Ex: cannot say withhold x but can ask if they typically owe money at the end of the year for taxes
What links are permitted to be sent to clients through DCC?
Only links to investor.vanguard.com, corporate.vanguard.com, and approved third party websites/links should be included in secure or non-secure client emails.
Advisors may send a link to the BETR Calculator on advisors.vanguard.com
ACTEC.org may be sent as a link for clients to locate trust and estate lawyers in the client zip code. Advisors may also send links to YouTube videos from the Vanguard channel (Vanguard - YouTube). No other YouTube video links may be sent to clients.
Crew may send links found on the investor.vanguard.com/investor-resources-education/events page. For crew awareness, direct links to upcoming webinar registration and previous webinars on the events page might not display the investor.vanguard.com URL.
How do you quote the advice fee?
What steps must an advisor take before going out of the office for coverage of tasks, appts, phone call activities, and emails when an advisor is out of the office?
The advisor must find buddy coverage. They should close everything they are able before going out of office and ensure their buddy is prepared to monitor for any new activities that arrive during the out of office time.
Owning advisors are held responsible for all items that are not closed within the required timeframe.
A client has an Enhanced Security Password. What is needed to pass through security?
Caller’s name, enhanced security password, and if the client selected the last four digits of SSN/TIN.
What is needed before an advisor can make permissible recommendations to a client?
A suitability conversation. Advisors must do sufficient discovery to ensure their recommendation is truly in the client's best interest.
What is allowed to be sent secure vs non secure?
If your response to a client's non-secure email contains any confidential information, including advice, asset or income information, an attached PDF file, etc., your reply needs to be sent Secure by updating the "Method of Communication".
Non-secure messages should only be used for general information, appointment confirmations, or non-account specific information.
What type of emails must be sent Secure?
What emails can be sent Non-Secure?
How must the Cash Plus Yield be quoted?
1. When quoting the APY in client conversations crew must state all the following:
•Term "APY" or “Annual Percentage Yield”
•Specify that the APY is for the “Cash Plus Program”, “Cash Plus Bank Sweep”, “Cash Plus Bank Sweep Program” or “Cash Plus Sweep Program” -- must be the EXACT words from one of these phrases when quoting the APY
•Provide the percentage to 2 decimal places. For example, 3.70% would be cited as “three-point seven zero percent”
•State the as-of date
•Disclose that APY may change at any time.
CREW CANNOT APPROXIMATE THE CASH PLUS YIELD
This is a bonus question. What is my middle name?
Vail