New Complex Products Review Process Begins January 2

The launch of the Complex Product Supervision (CPS) team is January 2. The CPS team is a dedicated group of professionals whose sole focus is to assist you with the review and supervision of complex products. As the regulatory environment continues to intensify, we want to ensure that you have a specialized group of professionals who understand the products and regulatory requirements in order to streamline the process and best ensure that your clients, your practice and the firm are protected. Our CPS team will work directly with you on the review and approval of all complex products.  

Which products will be part of the new process?

Beginning January 2, the CPS team will be responsible for the pre-approval review and supervision of transactions in the following product types:

• Variable Annuities
• Fixed Indexed Annuities
• Variable Universal Life
• Structured Notes
• Market Linked CDs
• Alternative Investments (Non-traded Real Estate Investment Trusts, Non-traded Business Development Companies [BDCs], Private Placements, etc.). 

How Will This Process Work?

• Financial professionals: We are streamlining the process so you will no longer have to work with your front-line supervisor for the required pre-approval of these complex product transactions. Instead, you will work directly with your dedicated CPS team members. Your OSJ will remain your central point of contact for all supervisory or compliance-related matters. As part of this transition, we want to ensure you are fully leveraging Unio and its efficiencies in order to streamline your document uploads to the platform while maintaining accurate books and records for your practice. Please look out for upcoming training sessions and resources.
• OSJs: While you are still responsible for the overall supervision of your financial professionals, you no longer need to review complex product transactions in Unio. The associated paperwork (Transaction Cover Sheets (TCS), account application, rollover disclosure form, etc.) can be excluded from your daily tasks. The CPS team will provide a review consistent with firm policies and regulatory expectations, and work through any issues with you and the programs to ensure alignment and transparency.
• We are dedicated to providing a best-in-class service and partnership to our client’s, the financial professionals. Our service level agreement is to review all transactions within 48 hours of submission. The CPS team will be a new consultative resource for your programs to leverage.

For assistance with completing paperwork, please review the guidance provided in the TCS Best Practices link.

Please also register for our upcoming training session, Processing Complex Product Transitions Using Unio, to learn how to properly use Unio and best practices with complex products.

Prior to January 2, we will begin a phased approach on limited complex product transactions to ensure the best possible field support and successful rollout. You may notice some new names approving documents and reaching out to you during the review and approval process, However, your program will be notified prior to any such transition. We will be working closely with your office, your existing OSJ(s) and program managers to ensure that the transition is as seamless as possible.

We are excited about the CPS Team and the enhanced processes. We know you and your clients will benefit from these changes.

You can contact the Service and Support team for questions or guidance on generating and uploading paperwork via Unio. For suitability or transaction-related questions, please reach out to your OSJ or dedicated CPS principal. You may also contact us at CPS@atriawealth.com.