Due to some recurring issues over the last few weeks, we wanted to remind you of the following important information regarding policies and procedures relating to check receipts for client accounts:

  1. Do NOT hold any client deposit overnight in your office or possession under any circumstances. Please note that for advisory accounts, the firm is deemed to have custody when it (or a related person) has possession of client funds or securities, even if held on a temporary basis. Accordingly, if a check is not received by the custodian within (3) days, the firm is deemed to be in violation of the Custody Rule (Rule 206(4)-2 of the Investment Advisers Act)and subject to a surprise custody audit, the cost of which will be assessed against the representative responsible for the violation. 
  2. Do NOT accept checks payable to Level Four or your DBA if you use one. You can only accept checks payable to Raymond James or the client account name. If the client account is an advisory account, checks should be made payable to the appropriate advisory custodian (Raymond James, TD Ameritrade, Fidelity, TIAA). The ONLY exception to these rules is that fees for services provided under a LFAS Financial Planning Agreement may be made payable to LFAS. 
  3. ALL checks received must be logged in on a check received blotter and a copy of the check (front and back) and log must be forwarded to admin@levelfourfinancial.com on the day it is received from the client. 
  4. ALL Checks in Transit (CIT) must be overnighted AND include a tracking number for reference.
  5. You cannot alter the check in any way once you accept it (no adding a date, account number, etc.)
  6. Any changes to the check must be initialed by the client and dated.
  7. For accounts custodied at Raymond James, you are able to review the list of “acceptable and unacceptable” checks within the Advisor Access platform on the RJ site.
  8. If you are NOT sure about a check, please contact your Branch Manager or Compliance Administrator (admin@levelfourfinancial.com) PRIOR to accepting the check for deposit.
 
Thank you in advance for your compliance with these important policies and procedures. If you have any questions related to the information contained in this Alert, please reach out to Stacey Lavender, CCO, Brokerage, Jill Zacha, CCO, Advisory or your Branch Manager.