The Complii system is an invaluable bridge connecting management within AFSLs to their advisers and clients. The transparency that this provides far exceeds both general and specific enquiries of ASIC's markets teams. The System has been developed by ZettaServe, a national IT firm, as an SQL database that links to your existing platform providers such as IRESS (Advisor), GBST Advisor, ETrade, Comsec, Core Equities, Pershing's and your settlement, clearing and execution house if need be. Having everything together in Complii will help not only in the retention of data for compliance purposes but in the streamlining of business operations also.
The online system is cloud hosted and develop by www.ZettaServe.com who boast clients such as BHP and RIO Tinto. All compliance and data is secure and recorded for alerts and user access. All processes, procedures and changes are time and date stamped, facilitating internal audit requirements as well as providing relevant reports to external bodies such as ASIC. All events and documents are also stored when the system is backed up off site in real time increments and at the end of day. The ASIC requirement to keep seven years of retained records can easily be met using Complii.
Each user can have a different level of access and permissions.
The most important and most used function of Complii is the Outstanding Advice report. Here line by line orders are input into complii for the advice to be recorded against with all statutory advice requirements adhered to.
The system logic is smart enough to know that an SOA is due for a retail client for the first trade/advice given or, if under $15,000, a Record of Advice is due. If the client is not a new client, but new to the Complii system, admin users can set the system to recognize this client having received an SOA via the previous system your AFSL used so the system will only offer an ROA or no advice given rather than keep offering an SOA when one has been given previously.
The Profile Exception Report highlights all clients that do not have a client profile on file with your AFSL. The client's account will remain listed in this report until they have had their profile uploaded or you choose to set them as either a General Advice Client, Sell Only Account or, should they meet the required criteria, a 708(8) or 708(10) client.
Upload your deal sheet spreadsheet and after creating your offer letter for a placement or IPO and email hundreds of clients their personalized offer letters in seconds. Each offer letter will be personalized, have a unique Bpay or Direct Credit Code and have a personalized acceptance form for the client to sign and send back.
This simple report extracts all clients with 708(8) certificates on file and sorts them by expiry date. It needs to do this as the 708(8) accountant's certificate is only valid for 2 years before it expires. It also displays all wholesale clients and 708(10) clients
The system is setup to show those clients whose 708 certificates have expired in red and highlight any 708 8 clients that may have received offers or advice when the 708 8 expired. Special treatment is also built into the logic to deal with 708 8 clients that are by the fact being a super fund are eligible under chapter 7 for exempt placements but still needing to be treated as retail clients for chapter 6.
Detailed and possibly the only true industry compliant system for dealing with 708 10 clients
Deal with clients that have not passed AML and using the data input and upload to pass AML.
Here all draft SOA's are listed waiting for approval from Compliance to send out.
As part of the Complii package there is a very robust Chinese Wall Register and notification system with the ability to add stocks and people to it if they are across the wall. Upon entry to the register a detailed email will be sent out to the people chosen on the notification list informing them that a new entry has been made in the register for the particular stock. The people who are across the wall are then sent an email informing them of their obligations. Any orders placed on those Chinese Wall stocks will generate an email alert to compliance.
An electronic version of the breach register.
The Corporate module allows for the entry of non-market transactions such as placements, IPOs and Off Market Transfers into the system. From this page you can enter the details necessary to generate offer letters for clients and to email them out to clients. All conflict of interest information is imported for the firms and advisers holdings are here. Hundreds of Offer letters for placements and IPO's can be generated in a matter of seconds via a spreadsheet/deal sheet upload into the system or by one client at a time. Bpay payment codes are generated inside the offer letter and the acceptance letter also.
Disclosure of conflicts of interest is one of the primary concerns for ASIC and FOS at the moment. Complii is designed to disclose the necessary information concerning your advisors' and your company's interests in all forms of communications to clients. For the conflicts of interest module to work all that is required is for the employees account number to be listed and as a "principal" account and complii will do the rest importing HIN holdings in. Conflicts can also be disclosed for commissions received from companies or soft dollar benefits. For example advisor A and Advisor B and AFSL licensee XYZ each have 100,000 shares in ABC Pty Ltd. The system will add those 3 x 100,000 ABC shares and then display in the Conflicts Of Interest 300,000 shares.
If an order is imported into the exceptions report for a retail client and it is over $15,000 the dealer's assistant or the adviser will be offered an SOA to complete. When completed it will go to the Pending SOA report and the compliance manager or responsible manager has the opportunity to view and edit and when happy accept that SOA and send it off to the client. At that point the client is emailed a copy and the copy is saved to the clients profile in the Complii system. No complying placements are also highlighted before the formal offer letter goes out. See below.
The report system that allows compliance to generate all reports needed in monitoring advisers. It can generate all orders, SOA's, complaints, General Advice, Notes Record of Advice and orders for any required period of time. It can also do this by adviser or stock or date.
Here advisers are able to generate an SOA or an ROA when advice is given that doesn't result in a transaction.
Complii has an integrated complaints handing system. Every incidence of dissatisfaction must be recorded so as to monitor advisers and provide a record of the event should the Financial Ombudsman Service or legal proceeding be actioned.
All associated accounts are set to the account status of "Principal". Since the implementation of Complii all "principal" trading is immediately displayed to the responsible manager and the nominated compliance assistants via the Principal Trading Exception Report.
Complii will annually asks people to update their client profile as required by the Corporations Act. This is done via email that also includes and a link to update the profile online with a new hard copy client profile or via a 708 8 form along with a copy of the current client profile that is one file. The emails states that this is an annual request email and if your situation has changed send back the new client profile or click on the link below to take you to a an online update that records the clients IP address to update it online.
Here you may just want to keep internal notes that are not seen by the client. This allows you to create that note and have it saved and time stamped.
All correspondence out from Complii will come with a link for the client to complaint directly to the compliance officer.
There may be instance where an order needs to be created. Perhaps an off market transaction or other. An advisor can create a "New Order" for a client directly from Complii and if need be handle the advice and regulatory obligations that go with the order.
When a client opens a second or third account with your AFSL, you may want to be able to group these accounts so they can easily be identified and used providing they are truly the same person with the same client profile and financial objectives.
The first order for a new retail client of over $15,000 will result in the Complii system offering up an SOA to be completed. In the case that the client has already received an SOA perhaps from your previous system complii can remove the need to send a second and unnecessary SOA out. If an authorised person clicks on the "remove SOA" link then that client's next advice order will not come up as the default for an SOA but rather a Record of Advice in the case of the client being a retail investor.
The Off market transfer page is a very simple system. It is as easy as imputing the buyers account number with the sellers account number, entering the stock code and then the volume. You then hit the generate the off market transfer button and an off market transfer will be emailed to the Adviser and the person who is logged into complii operating the system. The Off Market Transfer Form will be generated in MS Word and saved to the Offer Letter and Off Market Transfer history of the buyer and the seller. This can then be downloaded again and saves as a good history and tax record for the client.
One of the most exciting modules Complii has is the compliance module. When an AFSL license applies for a license a detailed compliance plan and or compliance manual is presented to ASIC with details on how the licensee will monitor and the frequency of the monitoring. Until now there has been no way to accurately record this information, ask the correct questions,
Due Date Wednesday, 29 February 2012
Frequency Every 3 Month(s)
Assessment - Please answer the following questions and provide comments where applicable.
1. Have we established effective systems and procedures to capture Suspicious Matters and report them to AUSTRAC? Fully Compliant Non Compliant
Question Comments Fully compliant
The ability to send EDMs (Electronic Direct Marketing/Mail) is a feature in the Complii system which allows advisers to bulk-send marketing/research emails to their clients.
Prior to scheduling an EDM send, clients should be assigned to specific Client Categories via the View Client page. This allows an EDM to target specific client groups, e.g. an EDM can be created intended to target clients which have been assigned to specific categories, such as 'Company directors' or 'Authorised Representatives'.
View General Advice Clients
View Client File Exception
View Limited Info Exception Report
View FSG Exception Report
Client Email Exception Report