Compliance – Branch file Memo

Branch File Memo

To: Registered Representatives/Branch Office Managers
From: Compliance
Re: Branch Office Files

One of your most important functions is supervision of the representatives and maintenance of respective documents at your office or location. In addition to the branch office checklist previously provided, listed below are files that Western International Securities, Inc. (“Western”) requires to be maintained at each branch location. Additional information can be found under Compliance section of Western’s website, www.wisdirect.com.

A. Order Tickets and Blotter

Order tickets and/or trade blotters for all securities transactions, including mutual funds, variable annuities and direct participation programs should be maintained and reviewed by the Branch Manager daily. The Branch Manager can evidence review by signature or initials. Procedures for Direct Business Processing are attached.

B. Customer Account Files

Customer account forms should be completed in their entirety, including signature of customer, representative, and principal. Account folders should contain appropriate verification of identity information (Passport #, Drivers License # etc.). In addition, each client folder should contain relevant information that the named customer or customers, including corporate entity’s and authorized traders, does not appear on the US Treasury OFAC list. Customer names can be checked against the list using the following web-link, http://apps.finra.org/rulesregulation/ofac/1/Default.aspx. Customer account files should contain:respective customer application and Western Client Agreement, applications related to mutual funds, variable products and direct participation programs, REIT’s and any other direct business applications. In addition, all related disclosure documents/worksheets related to the transactions should also be included. Disclosure forms can be found in the Compliance section on Western’s website.

C. Correspondence

Branches are required to maintain a centralized incoming and outgoing correspondence file
maintained chronologically. Outgoing correspondence should be reviewed and approved (through signature or initials) by the Branch Manager prior to being sent. Incoming correspondence is to be reviewed by the Branch Manager upon receipt. Non-OSJ offices are to send incoming correspondence to the designated OSJ. Any indication of a customer complaint should be forwarded to Compliance. Emails and instant messaging are considered correspondence, representatives are to use only Western approved email addresses. The use of personal email address for business purposes is prohibited. If you need assistance with Smarsh login features, please contact Rinaldo Ritonga.

D. Advertising

Branches are required to maintain advertisements (including websites, business cards and stationary, sales literature, seminar texts, newsletters etc) in a centralized file. Copy of advertisement and approval should be maintained together. Please remember to submit advertisements to Compliance prior to use.

E. Checks/Securities Received and Delivered Blotter

Branches should use a Checks/Securities Received and Delivered Blotter to record the receipt and delivery of customer checks and securities. Branch Managers can download these forms from the document library on www.wisdirect.com website. Please ensure these blotters are current and transactions are approved. Non-OSJ branch offices should send copies of the blotter to the designated supervisor. As a reminder, checks and securities are to be forward to the issuer or clearing agent by noon the next business day. Checks that are received and made payable to Western should be sent back to the client with instructions that checks are to be payable to the clearing agent. Copies of the blotters can be downloaded from wisdirect.com/western-forms/compliance.

F. Complaint File

Branches are required to maintain a customer complaint file. Any complaints received should be forwarded to Compliance. Please ensure that for each complaint included in the folder contains all documentation relating to the complaint, including the complaint itself, related correspondence with Compliance and any resolution of the complaint. A complaint is defined as any written statement from a customer or any person acting on behalf of a customer alleging a grievance involving activities of those person under the control of the firm.

G. Files as applicable: Telemarking/Do Not Call List; Gift Log; Signature Guarantee
Log;Branch Bank Account Statements; Political Contribution Log

As applicable, branch offices are to maintain the above-referenced files.

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