The VSA was launched in 1995 and has grown to become "the most comprehensive sales support tool in the industry. We have always taken great care to make certain all of our material is "in compliance." We have been aided in this effort by the broker-dealer compliance departments of many of our clients.
We provide no "product information" and, in 20 years of providing "conceptual content" for use by our subscribers, we have never had a legal issue with any of our content. We do not provide "timely" material that must be reviewed constantly, but rather "timeless" concepts that are only subject to tax and statistical updates. This, plus the fact that only a small fraction of our content is of an investment and securities nature requiring FINRA approval, has allowed our clients to essentially "block approve" the thousands of concepts in our offerings. Click here for a list of our client companies and associations.
Moreover, see Must all retail communications be filed with FINRA?. Our content meets the exclusion ("retail communications that do not make any financial or investment recommendation or promote a firm's product or services"). If your compliance office feels any of our material, other than those listed below, should be submitted for review, we will:
Please have your compliance office call us at (888) 998-6521 to discuss, as this offer is limited to specific content pieces.
We do have FINRA review letters provided to us for content deemed "reviewable" by the broker-dealer compliance departments of our clients. Copies of those letters are below:
Note: If a broker-dealer requires FINRA review on other content, the B-D should submit to to FINRA. When the "review letter" is received, we will make any changes suggested by the FINRA reviewer and would appreciate receiving a copy of the review letter.
Use of VSA resources with the public is subject to the approval of each broker-dealer. For enterprise sales of 25 or more seats, on request we will provide our broker-dealers with a "disclaimer coversheet" similar to the generic one located here. This "disclaimer coversheet" appears as either the first or last page of all VSA PDF content meant for public use. Additionally, for large enterprise editions, we are able to block some objectionable sections with a custom Main Menu.
The VSA-provided website has been reviewed by numerous compliance departments and all content has been carefully chosen to qualify under FINRA's Are there any exceptions to the principal approval requirement for retail communications?".
We rarely change our Website content, except to update it for tax and regulation changes. However, we maintain a list of compliance officers and, upon request, we notify them via e-mail when we institute any changes or updates. The website contains:
Optional content that can be disabled if you wish includes:
In addition, we hired Financial Regulatory Services (formerly BISYS Regulatory Services) to have the entire contents of the VSA reviewed and submitted to FINRA (formerly NASD). In August, 2006 Financial Regulatory Services (formerly BISYS) received a Comment Letter from FINRA (formerly NASD). The results for that review, together with the changes made to the content as a result of the review, are available below. The only subsequent changes made to the client presentations covered by the comment letters have been annual tax and benefit updates.
We have some producers who seek approval on an "as used" basis. They simply e-mail presentations they have prepared for clients to their compliance officers and usually get same day approval for that individual piece. They provide their compliance department with a link to this page in advance in order to lend credibility to the compliance efforts and increase the compliance officer's comfort level in the overall product.