Account Acceptance and Review
This new account opening document is the first document in each package provided to a client prior to opening an account. This document is placed on top of a cover letter and should be the first document a client sees whether they are receiving account opening documents by mail or digitally.
What is the Client Relationship Summary (“Form CRS”)?
Marquette employees who are authorized to speak to the media without approval from the President.
Who are no Marquette employees?
We receive an unexpected and out of character request to transfer funds to a new third party.
What is call the client to confirm that he/she initiated the email or mailed the request?
Request pre-clearance through Schwab CT for a sector-based ETF.
What is the process required prior to making a trade? While Marquette understands that even with thematic or sector ETF’s the risk of moving the market is deemed low. However, pre-approval is still required.
An example of when good client service causes us to have “deemed custody” and makes us subject to a Surprise custody exam.
What is possession of login credentials to outside accounts to link accounts in eMoney.
Clients and other signers must be informed of their option to receive and sign paper documents and documents containing Personally Identifiable Information should be secured with passwords in accordance with Marquette’s Privacy Policy.
What are the requirements for requesting and relying on e-signatures?
Statements which are promissory, exaggerated, flamboyant, or contain unwarranted superlatives. Unsubstantiated recommendations. Projections or predictions as to future results. Testimonials concerning Marquette’s advice or service and social media endorsements.
What are examples of prohibited advertising.
Requires Marquette to have an Identity Theft Protection Program (“ITPP”).
What is SEC Regulation S-ID?
When an employee who establishes or closes an account in which Securities will be/were held should provide the CCO with a Holding Report.
What is no later than 30 days after the end of the calendar quarter in which the account was opened?
Engagement planning, Initial due diligence, Contract review and negotiation, ongoing monitoring, documentation, and reporting.
What are Vendor Risk Management requirements?
Client service personnel are responsible for account coding on Tamarac, ensuring that client data is added to Salesforce and ensuring that necessary documentation is on file. Client service associates work directly with Relationship Manager and/or Investment personnel to resolve issues identified.
What is the Account Setup and Review Responsibilities of client service personnel?
The three places that client correspondence is saved.
What are:
For Red Flags raised by someone attempting to open an account, Marquette will Review the application, Deny the application, Report the applicant, and notify the client by notice required under state law.
What are procedures to prevent and mitigate Identity Theft?
All employees, interns, and contract employees of Marquette.
What is an Access Person? Marquette understands that this definition is broader than the generally accepted definition, which would generally include directors, officers, and partners only. Marquette’s administrative staff has access to significant amounts of account information; therefore Marquette considers it appropriate that administrative staff be subject to the same restrictions.
Documentation as to the reason a new technology or service is needed along with evaluation of potential vendors.
What is a Business Case?
This analysis should include a comparison of current fees and proposed fees if sufficient information on current fees is readily available to warrant a valid comparison. Such comparison should include internal fund expenses as well as explicit investment management fees. In the absence of sufficient information on current fees, the analysis should clearly disclose all fees in the proposed account.
What is the Fee Disclosure?
Marquette does not review or monitor personal social media accounts or text messages on employee-owned devices. However, Marquette imposes these restrictions on what employees can say about Marquette on those or similar social media sites as well as through text messages.
What are employees should not mention their employment, programs or activities related to Marquette on their personal social media accounts? And what is employees are not allowed to text clients other than logistical questions related to meetings?
An investment advisor, an investment advisor representation, any employee or direct of Marquette who may come in contact with a senior citizen as a regular part of their professional duties or anyone who may review or approve financial documents, records or transactions of a senior citizen.
What is a Reporting Individual?
Information that has not been generally disclosed to the investing public. Information found in a report filed with a regulatory agency, such as the SEC, or appearing in a press release or publication of wide circulation would be considered public. Such information must be in public circulation for a period of at least 24 hours before an employee may execute a transaction. To the extent employees communicate non-public information to other MAM employees, the recipient of the information is subject to the same restrictions.
What is non-public information?
When we are entitled to fees.
What is the day the account is open?
Name, physical address, OFAC review, driver’s license, tax identification number, occupation, source of wealth, etc.
What is Customer Identification information requested and reviewed for new clients?
Within one day of receipt of the complaint, the employee will discuss the nature of the complaint with their respective manager to develop an appropriate response. The employees will notify the CCO by memo outlining the source and nature of the complaint and the proposed actions. The employee will provide updates on resolution to the client at least weekly until the matter is satisfactorily resolved. Final resolutions are reporting to the CCO.
What are requirements for resolving verbal or electronic complaints?
If one of the common signs of financial exploitation is detected by a Reporting Individual and leads to a suspected belief that the senior citizen is being financially exploited, then the individual shall complete this.
What is the Report of Financial Exploitation of Senior Citizens?
An employee becomes aware of a violation of the Code of Ethics by a MWM employee.
What is employee must to report the violation to the CCO?
Person responsible for managing client portfolios in accordance with the Investment Policy Statement, ensuring cash additions are promptly invested, ensuring cash is available for documented cash needs, obtaining owners written direction for directed trades and, where appropriate, attending at least one client meeting annually.
Who is the Portfolio Manager?