9. Update your ADV form for lawyers: Consultants should include disclosure of referral agreements in points 5 B(6) and 8.H of the ADV form, Part 1A, and section 14 of the ADV Part 2A form, including a discussion of conflicts related to this agreement. The NASD Regulation considers it important to regulate the conduct of compensation related to securities transactions by their members to unregistered persons and that compliance with a referral fee rule, as described above, would significantly reduce the risks associated with inviting securities transactions by unregistered persons. 3. No agreement or insufficient agreement. The OCIE also found that consultants paid fees to lawyers without written agreement or using an agreement that did not contain the provisions normally required. Referring Client refers to an Investment Advisor from Acorns who has entered into the Investment Advisory Agreement, which is Appendix A of the Program Agreement and decides to make recommendations. In addition, this agreement uses the terms “you,” “you” or “you” as a reference customer. The NASD believes that it is important to be able to desolate the flow of securities-related remuneration, to pay those not registered by its members in connection with the recruitment of securities transactions. This is why, in the published interpretations, NASD has consistently defended the position that it is not appropriate for a member or person related to a member to make “finder” payments or transfer fees to third parties that will introduce or designate potential real estate customers to the company, unless the recipient is registered as a representative of a NASD member company.3 This position is based on the definition of “representative” or “representative” of the costs recommendation to third parties.
that introduces or refers potential customers to the company, unless the recipient is registered as a representative of a NASD member company.3 This position is based on the definition of “representative” in the NASD rules and the definition of “associate person” in the NASD statutes. In particular, Article 1031, point b), defines a representative of a member company as: the proposed rule prohibits direct and indirect transfers. Therefore, the rule prohibits both compensation paid directly to an unregistered person and payments made indirectly to an individual or organization specifically intended for post-payment to an unauthorized person. However, the proposed rule would not prohibit non-NASD financial institutions from paying transfer fees to their own employees, as provided for in the non-deposit investment product retail interposition statement (February 15, 1994). The amount of the premium is the amount of the recommendation incentive as indicated in the corresponding recommendation action. The lawyer assumes the legal risk of referring the business to an investment advisor for a fee. In order to avoid legal complications, I recommend that the appeal agreement include representation of the lawyer, that his activities be consistent with national and federal law. Here is an example: counsel should also require counsel to declare that they are not subject to any of these disqualifications in the invitation agreement. Beyond legal considerations, consultants who want to protect their reputations will not want to hire lawyers who have black spots on their files. Acorns will only credit your Acorns Invest account with premium shares when the referring client and the returned customer have met all the eligibility criteria under the terms of the respective recommendation action, which will vary depending on the promotion. After each referred customer (1) has opened a type of Acorns wallet account, (3) the etf shares that Acorns purchased in your name retain the type of subscription paid to Acorns for the number of billing periods with the initial investment for at least 30 days and (4) which are shown in the corresponding recommendation action.
acorns will credit your Acorns Invest account with the amounts and types of premium units corresponding to your selected portfolio and