As of November 1st, 2022, GRP has updated its policy regarding the recommendation of rollovers.
GRP has selected the Fiduciary Decisions’ Rollover Decision Support System (RDSS) tool to assist its Investment Advisor representatives (IARs) to evaluate and document whether staying in-plan or rolling assets into an IRA is in the best interest of a given client while staying compliant with current regulatory regulations
All rollovers to an advisory account under a GRP Investment Advisory Agreement now require documentation in the tool, whether it is a roll out from a plan or IRA to IRA transfer from another firm.
Before You Get Started:
All GRP Investment Advisor Representatives are required to watch the New GRP Rollover Procedures video available on our website, as well as all of the training videos provided in the link below prior to engaging in any rollover activity.
Step 1. Watch the “New GRP Rollover Procedures” video hosted by Cosmo Gould, Chief Compliance Officer below:
Step 2. Complete the training videos provided by Fiduciary Decisions by clicking the link below:
Step 3. IARs will be required to complete a Certification of Completion attesting that the required training has been completed.
Important Details Regarding the New Policy and Procedures:
The tool provides for the documentation of two rollover options: (1) an unsolicited rollover and (2) a recommended rollover.
- Unsolicited Rollovers – The unsolicited option should only be selected in instances where no recommendation was made.
- IARs can still provide clients with general information and education regarding distribution options including rollovers.
- IARs can explain their services should a client decide to rollover or transfer their account and work with them.
- If unsolicited is selected, IARs must avoid giving a recommendation of any kind regarding the client’s decision to move their account.
- The Unsolicited Rollover form generated through the RDSS tool has replaced the “Rollover Disclosure Form” which will be retired as of November 30, 2022.
- Documentation – In all cases involving a GRP advisory account, the client must sign a disclosure generated through the tool, either acknowledging an unsolicited rollover or the report generated as a result of a recommended rollover. You will have the following option to gather client signatures:
- Use DocuSign available in the tool
- Print and upload the signed disclosure back into the tool
- Plan to Plan Rollovers – Documentation in this tool is required in cases where an IAR makes a recommendation to a plan participant regarding a plan-to-plan rollover. If the IAR only provides education or information to plan participants, the tool would not be required.
For Individuals registered with LPL
LPL policy currently prohibits the recommendations of rollovers. As such, if any portion of a rollover may be going to an LPL brokerage account, you are prohibited from making any recommendation regarding rollovers and are limited to providing information and education only. You would however use the tool to document any resulting unsolicited rollover to a GRP advisory account.
If 100% of a rollover will be going to an LPL brokerage account, then this tool would not apply but you are limited to providing only education and information and must refrain from giving a recommendation.
Rollover recommendations will only be permitted if 100% of the funds will be rolled into an advisory account and properly documented within the tool.
Questions regarding the new policy and procedures should be directed to GRP Compliance.