Financial Services Online ("FSO") launched its services in 1995, which have grown to become the most comprehensive sales support tools in the industry. We have always taken great care to make certain all of our material are in compliance and have been aided in this effort by the broker-dealer compliance departments of many of our clients.
FSO provides conceptual content for use by our subscribers and we do not promote any specific financial product(s). We do not provide timely materials that must be reviewed on a frequent basis, but rather we provide timeless concepts that are only subject to tax, inflationary and other statistical updates. A small portion of our content covers investment and securities topics requiring FINRA review, with all of our non investment and security related content having no review requirements by FINRA.
Moreover, see FINRA's Rule 2210, Section C.1. 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 broker-dealer's compliance office feels any of our material should be submitted for review, we will:
The broker-dealer will need to submit the documents to FINRA. When the review letter is received, we will make any changes suggested by the FINRA reviewer and FSO will require a copy of the review letter and permission to provide it to VSA subscribers and prospects.
Please have your broker-dealer's compliance office call us about any additional questions at (888) 998-6521
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:
FSO 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.
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 can appear 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 Rule 2210, Section C.1.
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:
Use of VSA resources with the public is subject to the approval of each broker-dealer. 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.