'Trusted Contact' is an industry term that refers to a person we can contact in the following limited situations:
- Address potential financial exploitation issues
- Confirm specifics of current contact information
- Obtain health status
- Acquire identity of legal guardian, executor, POA etc.
Think of a Trusted Contact as the neighbor you leave a spare house key with: they can assist in the case of an emergency, but they don't have the authority to sell your house on your behalf.
FINRA established a set of rules that requires Custodians to ask for and/or obtain trusted contact information if a person is age 65 or over. The SEC decided they want the rule to apply to RIA firms as well, and added the extra stipulation of age 65 or imminently retiring (if the relationship includes Assets Under Management).
As a firm, we recommend requesting Trusted Contact information for clients age 60 or older. The requirements do not dictate that we must actually obtain the information, just that we must request it. Trusted Contact at the firm level is not the same as Trusted Contact at the Custodian; having a Trusted Contact for the firm does not authorize the Custodian to contact the Trusted Contact and vice versa.
How to request a trusted contact
Because the requirement is only to request Trusted Contact information, we, as a firm, administer the Trusted Contact process through a Cognito Form: Permission to Share Client Data.
The form works in an identical fashion to every other Cognito form that we use to obtain client signature:
- Follow link to create a new entry.
- Fill out all required fields, including: your information as the advisor or sender, which form you wish to complete, and the client's name and email.
- Verify the form is correct; enter Trusted Contact info if you already have it instead of using the form to collect from the client.
- Select 'Yes - Automatically route to client.'
Once you Submit, you've officially satisfied the Trusted Contact requirement.
If the client completes and submits the form, the advisor or sender is responsible for saving the completed form to the client's Investment Management folder in Egnyte. The .pdf copy is attached to the Cognito confirmation email once signed.
The status of outstanding Trusted Contact forms can be obtained through the Permission to Share Dashboard.
Adding trusted contact at the custodian
The form allows the client to check a box if they would like the same Trusted Contact record added at the Custodian level. This prompts the HQ team to generate and send a DocuSign to the client in order to complete additional paperwork.
Maintaining Trusted Contacts
Garrett HQ assisted in a jump-start cleanup project for all advisors the summer of 2021 by providing a list of all existing clients age 60 or older with Assets Under Management. It is the Advisor's responsibility to maintain Trusted Contact records on an ongoing basis however, which means having a process in place to request Trusted Contacts from clients who turn 60 throughout the year or new clients gained throughout the year.
Redtail CRM. As long as Date of Birth is entered in Redtail, you can utilize Quicklists or Advanced Search to run a list of all clients age 60 or older with the following parameters:
This will generate a list of ALL clients that have a relationship involving ISS, and are age 60 or older.
On an ongoing basis, you could use the following parameters to determine who has turned or will turn 60 in a given calendar year:
The year should be the current year (in the above example = 2022) less 60, equals the birth year.
Best practice is set a recurring annual calendar reminder to run the Trusted Contact list in Redtail, run the Advanced Search, export a list, and contact those clients.
Orion. In order to obtain a list of client birthdays in Orion, you can utilize a number of parameters or applications. The fastest is Portfolio App > Registration level.
The grid is preset to show certain account information, including date of birth for the investor. From here, you can simply filter the DOB column with '1962' to get a list of all clients born in 1962.
To simplify the list and remove duplicates (as one client may have multiple accounts), you could take it a step further and add a 'Grouping' by Name.
Orion also allows you to export a list and then utilize the data to contact clients as appropriate.
Many advisors have decided to take another route for ongoing maitenance, and here are some of their solutions:
- Request Trusted Contact information from 100% of ISS clients
- Include Trusted Contact as a step in client onboarding if the client is over 60 and opening accounts utilizing an onboarding workflow in Redtail
- Include Trusted Contact as a step in client account opening
As always, please reach out with any questions to Nicola@GarrettAdvisors.com or submit a Help Ticket!