Compliance Memo

Compliance Memorandum 2011-05; Updating and Reviewing a Client KYC Form

For more information, contact:

Compliance Team

Date Issued:

July 22, 2011

With regulators placing considerable attention on the Know Your Client Information as part of evidencing suitability, GP Wealth Management (GPWM) would like to remind all Financial Advisors of our policy and that supervisory staff would require an updated form:

  • a) when a Financial Advisor is made aware or believes a material change has occurred in the client’s circumstances
  • b)when the client makes GPWM or its Financial Advisor aware of a material change in their circumstances and
  • c) at minimum once every 36 months

Given the requirement to update the Client KYC Form at minimum every 36 months, we must have controls and procedures to adhere to our policy. In this connection, GPWM initiated a project working with systems programmers to identify all Client Plan(s) where the KYC has not been updated in the last 36 months as of June 30, 2011. As a result we will be employing a script that verifies the system KYC and will “freeze” all plans where the last KYC update is 36 months old or more. The script will run on July 29, 2011 after close of business.

In addition to identifying which client KYC information requires updating; reviewing and comparing a client’s KYC information with their plan(s) prior to making a recommendation is a mandatory regulatory requirement and GPWM policy for all Financial Advisor.

To help Financial Advisors with their KYC requirements, GPWM has:

  1. Developed a report to identify which clients may experience this “freeze”. A procedure guide to obtain that report below. Please see the “Client Review Date Report” procedure guide below to obtain a report for your clients.
  2. Upgraded its systems to provide a consolidated snap shot report to verify that a client’s plan(s) are in line with the KYC information. A procedure guide for the “Review Plan KYC” has been attached below.

As always, if you have any questions or comments, contact the Compliance Department by email at