New and Improved
NAM has adopted a Senior Investor and Vulnerable Adults policy. What age is considered to be a Senior Investor? A senior investor is defined as...
A senior investor is considered 60 or older
For personal trading purposes, what constitutes a household?
A household is anyone who lives in the employee's home which typically means any relative by blood or marriage living in the employee’s household including adoptive relationships.
NOTE: Personal relationships such as roommate situations when the employee does not have a beneficial interest or exercises investment discretion over the account are excluded.
Compliance is solely the responsibility of the CCO
No, Compliance is all our responsibilities
What is insider trading?
It is undefined under the law but it has come to mean trading on material non-public information
Do you need to tell anyone if you lose your cell phone or laptop?
You need to contact Karen, Blake so they can contact OS33 to wipe the phone/laptop
What is the full name of Form CRS or ADV Part 3?
The form is called the Client Relationship Summary and it is to be first used in June 2020
What is the guiding principle of NAM as found in its Code of Ethics?
At all times place the interests of Firm clients first
Is NAM required to maintain its books and records in perpetuity?
No, NAM must maintain its books and records for 2 years onsite and 5 years from the end of the fiscal year in which the record was created. A firm may keep them longer if the so choose.
You have been offered to serve as the President of the Cookie Bakers Charitable Foundation.
Can you accept the position?
No, unless you obtain prior written approval from the CCO.
NAM’s Outside Business Activity policy prohibits employees from engaging in any outside business activities unless you first obtain prior written approval from the CCO.
What is custody and does NAM have it?
Custody means holding client funds or securities, directly or indirectly, or having the authority to obtain possession of them.
NAM has custody through direct debit of its fees,
if an employee serves as trustee on a client account or
if it maintains 3rd party Standing Letters of Authorization (SLOAs) whether or not it meets the 7 conditions of the February 2017 IAA No-Action Letter (no surprise exam if meet conditions).
If NAM receives client funds or securities but does NOT return them to the sender within three business days of receiving them it is deemed to have custody.
Trusted contact are what kind of people
It is a person that a client has appointed who may be contacted about their account or health.
NOTE: trusted contacts may not transact on the account nor can we release any of a client's account details to a trusted contact. NAM may only use this information in an attempt to contact a client directly.
Who are considered Access Persons at NAM
All employees are deemed to be Access Persons
NAM has said in various formulations that “At all times, it and its employees, place the interests of Firm clients first”
Name 2 documents where NAM share this disclosure?
It is contained in the Introduction to the Compliance Manual, found in the Code of Ethics and in NAM's Form ADV brochure
Why does NAM have a clean desk policy?
It is designed to protect sensitive client data.
What is the dollar limit for giving/receiving gifts
Generally, Gifts given or received cannot be excessive or unreasonable but the limit is $300 unless pre-approved by the CCO.
What is a sign of possible financial exploitation
What are some examples of is private client information? For full credit, please provide 3 examples of such information/data
Name, Address, SSN, state issued documentation, DOB, Account Numbers, Bank Account Information
What is a client testimonial?
It is a statement of a client’s experience with or an endorsement of the adviser.
If a third party vendor such as a mutual fund sponsor has offered to pay for or reimburse you as an employee of NAM for conference registration fees or hotel, can you accept?
This is a gift and not business entertainment and must be pre-approved by the CCO.
Gifts of greater than $300 must be pre-approved and all gifts must be reported via SchwabCT.
How many days do I have to change my U-4 information
You have 30 days to report your address change, professional designations, life changes or legal and financial matters
what is a sign that a client may be showing diminished capacity
At the outset of each compliance training, I have identified "General Reminders" of compliance ideas to keep in mind. Indicate one of these key ideas to keep in mind for NAM's compliance efforts.
Document, document, document…
Get Credit for Doing Things Right!!!
or
SEE SOMETHING ….. SAY SOMETHING
How does NAM define a cyber event/incident
NAM defines cyber event/incident as unintentional or targeted disruptive events related to NAM’s technology and security protocols
If you want to buy an initial public offering in the latest Unicorn from Silicon Valley, do you need to ask for permission to do so?
Yes, you must seek pre-clearance approval using SchwabCT and not execute the transaction unless having received such approval
Forbes Magazine wrote a favorable article about NAM.
Can you "share" (i.e. post or tweet) the Forbes article on any of your personal social media sites?
No, articles, communications or content "Shared" by an employee on any personal social media site that contains language that could be construed as a “testimonial” is prohibited.
Testimonials are defined as an explicit or implicit statement of a client’s experience with, or endorsement of, NAM or its employees.