How to collect Trusted Contact information

How to collect Trusted Contact information

In February 2017, the SEC approved FINRA's proposed amendment to the Customer Account Information rule and created the new Financial Exploitation of Specified Adults rule, both of which went into effect February 5, 2018.

In response, Schwab instituted policies to comply with these new rules, including changes to forms allowing us to collect Trusted Contact information for all clients and the creation of the specialized Senior Investor Support Team.

Use the guided workflow on Schwab Advisor Center to complete the Add a Trusted Contact Person form.

Clients provide Trusted Contact information to Schwab via the Trusted Contact form or new account application. Any changes will require the client’s authorization.

Complete and send the signed form(s) to your Schwab service team via Schwab Advisor Center® service request.

View the Trusted Contact information for your client’s account on Schwab Advisor Center.

  1. Select your client’s account.
  2. Go to Profiles.
  3. Under Account Holders and Contacts, click the name of your client.

Note: Trusted Contact information is located on the Profiles tab for each individual account holder, not at the account level.

Once you have submitted the new account application(s), the following steps may apply:

  • The request will be reviewed and processed by Schwab. If you have any questions about the process, contact your Schwab service team.
  • A centralized team has been created to work with you to address client concerns, such as financial exploitation or diminished capacity. The team may contact you, for example, regarding a transaction where Schwab suspects a third party might be trying to unlawfully obtain assets through deception, or when a client shows potential signs of diminished capacity over a series of interactions. The team will review cases and then work collaboratively with you, your client, and potentially the Trusted Contact, to develop a plan of action. That plan could, for example, call for the account to be restricted or for a hold to be placed on the disbursement in question.
  • Depending on your regulatory requirements, some firms may need to escalate to various agencies, including, but not limited to, reporting suspected financial exploitation to Adult Protective Services (APS), State reporting agencies, etc.

To select a form, go to the Forms library on Schwab Advisor Center.

Form: Add a Trusted Contact Person
Resource: Compliance Review: Ongoing compliance updates for independent advisors
Resource: Protecting senior and vulnerable investors

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