Compliance

Compliance Supports

Here are the Rules

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  • Notify Jennifer Wisthuff or Mindy Vinson of Changes

    • U-4 Information/Updates
      It is the Registered Representative's responsibility to promptly notify the Agency Supervisory Officer of any updates to their Form U4.

    • Producer Address Change Form
      Complete the online form to update your business/residence address. Business addresses must be approved in advance.

    • Outside Business Activity
      To add, remove, or change an Outside Business Activity, email Jennifer Wisthuff or Mindy Vinson with your request and be prepared to complete a form.

    • Personal Securities Reporting
      Use Practice360 > Compliance tab > Personal Securities Reporting > Code of Ethics / Personal Securities Report > + Add New Account to report accounts to MMLIS and comply with SEC, FINRA, and MSRB rules and regulations regarding personal securities accounts. Private securities transactions must be reported and approved prior to making the investment.

    • Private Securities Transactions
      To request approval for a private securities transaction, use Practice360 > Compliance tab > Personal Securities.

    • Political Contributions/Solicitation
      Use Practice360 > Compliance tab > Political Contributions Disclosure > Political Contributions – Pre-Clear New Contribution to request approval before making a campaign or political contribution. Read the FAQ for more details.

    • Changes in Staff
      Notify us if you plan to hire someone or if we need to terminate someone from our systems.

  • Client File Management

    Client files must contain, at a minimum, all relationship documentation in accordance with the Field Compliance Manual - Client File Management

    For securities-related business, files must also meet additional regulatory requirements under SEC Regulation Best Interest (Reg BI).

    Regulation Best Interest Documentation & Workflows

  • Financial Planning– Compass page


    Information for your financial planning cases can be found in the Financial Planning Administration System (FPAS).

    Financial Planning Forms and Documents
    These can be accessed in the Practice360 Forms tab.

    Required Disclosures in DocuSign
    Be sure to include the required disclosures in the DocuSign Envelope:

  • Reporting Potential Issues and Red Flags
    If you suspect a problem or identify any red flags with your client, immediately notify an ASO.

    Examples of Red Flags:

    • Transactions that lack business sense

    • Payments followed by a surrender

    • The client insists on secrecy

    • Promises of large future transactions

    • No apparent, legitimate source of funds

    IMPORTANT: Never turn a "Blind Eye."

  • Security & Client Private Information (CPI)

    • Keep your mailbox locked.

    • All CPI must be kept under lock and key when you’re away.

    • Shred CPI when disposing of it.

    • Per HIPAA, Application Part 2 must be shredded 180 days after the policy is issued.

    • Notify us immediately if there is a confidentiality breach, whether electronic or physical.

  • Annual Requirements
    Each year, you are responsible for completing the following:

    • MMLIS CE Courses

    • Compliance Meeting (video)

    • Compliance Attestation

    • FINRA Regulatory Element

    • State Insurance Requirements (Note: MassMutual does not track insurance licensing renewals)

    • CRIA

    • IAR CE

  • Failure to Comply - Possible Outcomes
    Failure to comply could result in one or more of the following:

    • Letter of reminder

    • Letter of caution

    • Fine

    • New business restriction

    • Forfeiture of commissions

    • Special supervision

    • Suspension

    • Termination

  • What is a Customer Complaint?
    A customer complaint can include grievances related to:

    • Producer

    • Home Office

    • Products or Services

    Ways to Receive a Complaint:

    • Written Statement

    • Text Message

    • Letter

    • Email

    Next Steps:
    If you receive written correspondence that could be considered a complaint about you, the home office, or a product/service, notify us immediately. We will ensure it’s properly addressed.

  • MMLIS Direct

    MMLIS Direct enables Registered Representatives to purchase new FINRA exams and renew licenses.

    Licensing Central

    Licensing Central provides information about licensing, agent contracts, and registration status.

    Split Codes

    View or create new split codes.

    WMS Managed Account Training

    Before opening any managed (CRIA) accounts, required training must be completed on MMLIS Distance Learning. Navigate to: MMLIS Distance Learning > Course Catalog > MMLIS WMS Programs – Required Prior to Solicitation or Selling.

    Non-Proprietary Variable Product Appointments

    Non-Proprietary Variable products have requirements beyond having the appropriate licenses and registrations.

    Representatives must:

    • Have a state variable insurance license

    • Hold a state securities license

    • Be appointed with each carrier for the products they wish to sell

    Representatives are responsible for being appointed with the carrier before conducting business. Certain states may have additional requirements, and representatives should contact their Agency Licensing Coordinator for further details.

    Important: Appointments can take 4-6 weeks or longer to process if all paperwork is in good order. Representatives should plan accordingly and follow the steps below:

    1. Verify that you are state securities licensed and hold a variable line of authority on your insurance license in the state where you plan to do business.

    2. Get appointed with the carrier.

    3. Once appointed, work with the Agency Licensing Coordinator to complete the necessary form and submit it to MMLIS at AdvisorOperationsHub@massmutual.com

    Note: If these steps aren’t completed prior to doing business, it may cause issues with receiving commissions.

    Regulation Best Interest (Reg BI)
    Reg BI went into effect on June 30, 2020. Click the button below to access training resources, including the required training “Regulation Best Interest Overview,” along with sales tools like disclosures, RightBRIDGE, and the Regulation BI New Business and Subsequent Transactions Reference Guide

    Training Resources

    Provide your client with your ADV Part 2B (if applicable), the Reg BI Disclosure, and the MMLIS Form CRS. These can be mailed, sent via Docusign, or hand delivered, but cannot be delivered via email.

    Securities-Related Check Processing

    • Verify that the check is made payable to an approved carrier or vendor. Do not send it directly to the carrier.

    • For checks payable to NFS, you may mobile deposit using the A360 Mobile App or the Wealthscape App

    • Complete a CSR Form: Check & Security Remittance Form (Excel)

    • Follow the Flow of Funds policy – Core advisors, process same day. Detached Advisors must overnight the same day check is received, if not mobile deposited.  Please email a copy of the completed CSR and deposited check to the core for retention.

  • Annual Client Contact Requirement

    • Use only company-approved statements (A360 and Wealthscape) for annual reviews.

    • Producer-created statements are not permitted.

    • Contact must occur at least once every 12 months and be documented.

    • Use the Advisor360° CRIA Client Contact module to document annual client meetings. Corporate RIA Reviews | Advisor360°

    • If unable to meet, document all attempts to schedule the meeting.

    • If no contact is made within two years, contact an ASO to determine next steps.

    • Trade requests must be confirmed verbally before acting.

    • All requests for withdrawals or material account changes received in writing must also be verbally confirmed with the client to prevent fraud.

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FAQS

Jennifer Wisthuff

Vice President, Supervision & Compliance

Mindy Vinson

Supervisory Officer

Meet the Team