Regulation Best interest

New Obligations Effective 6/30/2020

As part of Reg BI, the SEC adopted four new obligations that impact you.

New Best Interest Obligations: We have an enhanced "best interest" obligation to retail investors that applies at the time of a recommendation of account openings, at the time of strategy recommendations, and at the time of an investment recommendation/transaction. The obligation is principals based, and is open to legal interpretation.

New Disclosure(s) Obligations: We must disclose material facts, including ALL fees, the scope of services and any limitations as it relates to the Firm and the Financial Professional. We must disclose the nature of the proposed relationship at or before making a recommendation, especially any conflicts of interest.

All associates must adhere to specific timing, format and record-keeping requirements of disclosure delivery. Our Disclosure Documents & Form CRS Jotform provides a streamlined method for you to stay compliant.

New Duty of Care Obligations: We know Reg BI will impose duties on representatives that significantly exceed the current suitability standard for retail brokerage clients as follows:

1. Explicitly requires that recommendations be made in the client’s best interest

2. Explicitly requires that costs be considered when making a recommendation.

3. Requires a RR to consider “reasonably available alternatives” when making a recommendation.

Centralized record-keeping of recommendation notes and documents becomes a Firm requirement.

Conflict of Interest Obligations: The Firm and the Financial Professional are required to identify and at a minimum disclose..or eliminate conflicts of interest. Conflicts may be related to material limitations on the securities or investment strategies you recommend to retail investors (not-dually licensed with Level Four, or business model related.) Your new Rep Disclosure documents will assist you with your personal disclosure obligations.

What you should be doing now?

1. For recommendations with a Level Four specific review/disclosure form, follow form instructions to document your recommendation. Anticipate form revisions. Anticipate account/product policy updates. Adjustments to processes, particularly around Duty of Care obligations will occur well beyond June 30th.

2. For recommendations without a Level Four specific form, use RJ CRM to contemporaneously document your considerations and discussions with investors. Include costs and alternatives as standard considerations.

3. Continue to work with client's to update investment profiles (missing or outdated information). Anticipate NIGOs (not-in-good-order) rejections of new business with missing data.

4. Continue to work with client's to update email contacts and authorizations to deliver future written disclosures.

5. Develop a repeatable business process that establishes consistency in your practice and demonstrates actions you take in clients' best interest on a regular basis. Define your process checklist for investment selection.

5. Complete your Rep Disclosure Profile. Participate in continued training, read Firm Disclosures, FAQs and Guides, and follow Firm instructions.

6. Role play/ practice your introduction of disclosures and Conversation Starter questions. Exercise key considerations in your recommendation process. Practice documenting contemporaneous notes in RJ CRM.

Level Four Form CRS & Additional Disclosures

Don't be late. Access Your Disclosure Delivery Obligations table help stay on track.

Your Reg BI disclosure obligations involve 4 layered deliveries:

1. Level Four Financial Form CRS (ADV3)-Delivery is required before or at the time a recommendation is made for a new account, initial direct investment, or investment strategy. Complete Level Four digital form Document Disclosures & Form CRS Jotform. ( See more info in Disclosure Delivery FAQs )

The Document Disclosures & CRS form provides automated electronic delivery of Form CRS and Important Investor Information disclosures on your behalf. (See Sample Email from Level Four)

The Document Disclosures & CRS form documents your manual/mail delivery of Form CRS and Important Investor Information disclosures when email is not elected. (See pre-approved Rep Delivery Cover Letter)

Form CRS has a number of required conversation starter questions. (to prepare see Rep Form CRS Discussion Points )

You are not responsible for delivery of Form CRS to existing clients (opened prior to 6/30/20) which will be scheduled in July. You may choose to notify existing clients in advance to reduce the number of inquiries you might receive. See the Optional Form Letter: Pre-CRS Notification.

2. Level Four's Supplemental Disclosure ("Important Investor Information") delivery is concurrent with Form CRS. This supplemental disclosure provides firm specific details regarding services, products, fees and conflicts.

3. Rep Supplemental Disclosure- Rep supplemental Reg BI disclosures may be delivered orally. The Rep specific disclosures include but are not limited to: your capacity (acting as broker or adviser); service/product limitations; additional compensation and conflicts of interest.

To assist with your custom Rep supplemental disclosure, the Firm used digital Rep Reg BI Disclosure Survey .

4. Product/Platform Specific Disclosures- As you have in the past, you are required to deliver all applicable product/platform specific disclosures to the investor (e.g. ADVs, Level Four product specific disclosure forms, prospectus, or offering circulars.)

Reg BI Training Resources

1. Reg BI Zoom Meetings and Q&A

2. Quest Firm Element CE: Reg BI-Ch.1

Quest Firm Element CE Reg BI-Ch.1 (For internal use only)

3. Compliance Meeting 9-13-19

Compliance Mtg Reg BI (pdf)

4. RJ CRM Training

5. Additional RJ CRM training- RJ Advisor Access required

Advanced Search How To Guide (PDF)
RJ CRM 103 Advanced Search Overview (6 min.)
Saving Searches (1:10 min)
Modifying Searches (00:43 min)
Creating Multi-Contact Tasks (00:42 min)
Working with Client Tiers (1:29 min)
Finding Available Balances (00:58 min)
Running Birthday Reports (00:47 min)
Creating and Managing Lists (PDF)
Use Case Scenario Slides (PDF)

New or Revised Forms as of 12/22/21

Level Four Forms and noted revisions

Disclosure Documents & Form CRS (NEW- Deliver Form CRS)

Raymond James Forms

1236CF- Rollover Certification-digital only

1529- 529 Client Disclosure (ALL 529s)

Brokerage Forms

Check the background of your financial professional on FINRA's BrokerCheck. We take protecting you data and privacy very seriously.

As of January 1, 2020 the California Consumer Privacy Act (CCPA) suggests the following link as an extra measure to safeguard your data: Do not sell my personal information.

Securities offered through Level Four Financial, LLC, a registered broker dealer and member of FINRA/SIPC. Advisory services offered through Level Four Advisory Services, LLC, an SEC-registered investment adviser. Insurance services offered through Level Four Insurance Agency, LLC. Level Four Financial, LLC, Level Four Advisory Services, LLC, and Level Four Insurance Agency, LLC are independent entities. | Disclosures | Representative Email Access

Level Four Group, LLC is a division of CRI Capital Group, LLC, a subsidiary of CRI Advisors, LLC. “CRI" is the brand name under which Carr, Riggs & Ingram, L.L.C. (“CPA Firm”) and CRI Advisors, LLC (“Advisors”) and its subsidiary entities provide professional services. CPA Firm and Advisors (and its subsidiary entities) practice as an alternative practice structure in accordance with the AICPA Code of Professional Conduct and applicable law, regulations and professional standards. CPA Firm is a licensed independent CPA firm that provides attest services to its clients, and Advisors and its subsidiary entities provide tax and business consulting services to their clients. Advisors and its subsidiary entities are not licensed CPA firms.