When setting up OverSuite, you complete a compliance wizard. It asks if you refer clients for investment services and if you receive commissions.
Your answers allow OverSuite to adapt your Terms and Conditions to include relevant disclosures. However, you still have a professional obligation to:
Notify clients of any commissions received
Disclose the actual amounts, not just the fact that commissions exist
OverSuite provides downloadable documents. These include commission notification letters and third-party introduction letters. They help you meet these obligations.
Key points and common questions
1. What counts as a referral?
Any introduction to a third party for investment services counts as a referral, even if you don’t receive a commission.
2. Do I need to notify clients of all commissions?
Yes. Notify clients whenever you receive a commission, even if it’s rare.
3. Do I need to disclose referrals if I don't receive a commission?
Yes. Disclose that can refer clients to a third party when completing the OverSuite wizard.
4. Do I need to disclose the value of commissions?
Yes. Disclose the actual value to each affected client. For recurring commissions, you can notify them periodically.
5. What about third-party payroll providers?
If you outsource your payroll work, include a statement in your Payroll Data Processor Agreement. OverSuite allows you to add this agreement and edit your content.
See also
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