It has come to our attention that a number of Representatives are using one‐time PACs in order to make purchases into client accounts.
While we understand that some clients may not have chequing accounts and prefer to have the funds debited electronically from their bank account, this creates supervisory issues for the dealer, as these trades circumvent our electronic supervision and do not appear on the daily trade blotters.
As a result, all one‐time PACs – whether they are an initial PAC or additional purchase into an existing account – must be submitted to your Regional Compliance Officer/Branch Manager for Tier 1 approval before they are submitted to the fund company for processing. Where appropriate, the Regional Compliance Officer/Branch Manager will forward for Tier 2 approval. If you are a non‐processing rep, these trades should still be forwarded to your IP Team. They will forward the trade for approval.
If you are a Remote Order Entry (ROE) representative, these trades must be forwarded to your Regional Compliance Officer, at the geographic mailbox assigned to you. Once approved, the RCO will return the trade to you for processing.
If you have any questions, please contact your Branch manager or Regional Compliance Officer.