Compliance Memo

Compliance Memorandum 2011-02; Outside Business Activity

For more information, contact:

Compliance Team

Date Issued:

April 26, 2011

We would like to remind all financial advisors of some of the issues surrounding Outside Business Activities (“OBA”) including the use of trade names and their impact on advertising and sales communications.

OBA means any business carried on by a financial advisor other than business done on behalf of GP Wealth Management Corporation (“GPWM”). This may include insurance sales, financial planning, tax preparation, and certain other activities.

The most important aspect of the rules regarding OBA is that the activity must be disclosed to, and approved by, GPWM prior to the advisor engaging in such activity. Some types of activity cannot be approved; most seriously, securities related business conducted outside GP Wealth Management Corporation.

Because of the potential for client confusion, we must also provide all clients with our dual occupation disclosure. A copy of the disclosure is enclosed with this memo and will be provided to each new client with their welcome package going forward. Providing a copy of this disclosure to all clients and making copies available around the office in plain sight are best practices.

Trade names, advertising, and sales communications must also be approved by GPWM prior to use or transmission. Trade names include any name or business name by which you, or your company, are known. This includes phrases such as “the money coach” or “market watch specialist” that were common in years gone by. The key factor for regulators is that trade names and advertisements be both true and not misleading.

Advertising includes not only traditional print, radio and television ads, but newer media such as web and social media sites where you promote your business. All ads, regardless of the type of media, must be pre-approved by GPWM. Pre-approval forms are available on your personal website or by clicking here.


Dual Occupation Disclosure Form

As always, if you have any questions or comments, contact the Compliance Department by email at