November 22, 2021
A few annual reminders regarding important requirements relating to your advisory accounts. Please note that currently there may be different delivery methods as noted depending upon whether you are advisory registered with Level Four Advisory Services, LLC (“LFAS”) or whether you are currently advisory registered with Level Four Financial, LLC (“LFF”). As a reminder, all reps will be advisory registered with LFAS as of 1/1/2022 so LFAS docs and delivery method will be utilized exclusively starting in 1/1/2022.
Annual Account Reviews
Annual account reviews are required for all advisory accounts every year.
LFAS advisory reps
Those reps who are currently registered with LFAS should utilize the LF169 for annual reviews.
LFF advisory reps
Those reps who are currently advisory registered with LFF should utilize the LFF169 for annual reviews.
Advisory Disclosure Documents
The following disclosure documents are required for all advisory accounts. You must be able to document delivery of each of these documents at the time an account is opened for firm and regulatory purposes. **Note that these documents are in addition to any other account documentation that may be required either on the Raymond James or brokerage (LFF) side. Some documents may require delivery at other points during the advisory relationship as well (Form CRS).
LFAS advisory reps
You should be using the LFAS Disclosure document via Jotform for delivery of all of these documents at the time an advisory account is opened. You may also need to utilize at other points in the relationship as well. (Form CRS is required if recommending a rollover, or if moving an account from brokerage to advisory or to a new advisory platform).
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LFAS Advisory Form CRS (**note this is not the same as the LFF Form CRS)
- LFAS Form ADV Part 2A OR Wrap Brochure (i.e. ICA)
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LFCM Form ADV Part 2A *if account is managed by LFCM
- Form ADV Part 2B
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SBLOC disclosure documents (2) *if account is an SBLOC
LFF advisory reps
- LFF Form CRS (currently includes both brokerage and advisory disclosures)
- LFF Form ADV Part 2A or Wrap Brochure (i.e. ICA)
- Form ADV Part 2B
*Note that there is currently no automated delivery of the LFF Form ADV Part 2A/Wrap Brochure or Form ADV Part 2B so reps should be maintaining their own delivery logs for these documents. As of 1/1/2022, all reps will be advisory registered with LFAS and all will use the LFAS automated Jotform for delivery of all disclosure documents.
Thank you for your attention to these important regulatory compliance requirements. As always, please feel free to reach out to any member of the Level Four Compliance team if you have any questions regarding the content of this communication.
