Compliance Memo

Compliance Memorandum 2013-01; Exempt Products

For more information, contact:

Compliance Team

Date Issued:

January 31, 2013

It has come to the attention of GPWM Compliance that Qualified Financial Services, our approved MGA, continues to promote exempt products to our financial advisors who are mutual fund registered and who have an approved dual occupation to sell insurance products.

In light of this, we would like to remind all GPWM Financial Advisors that all securities related business which includes exempt products must be approved for sale by the dealer and can only be carried out through the facilities of the dealer (GPWM).

At this time, there are no exempt products that have been approved for sale by GPWM, however if there are any exempt products that you are interested in providing to your clients and you have the appropriate proficiency please let us know and we would be pleased to conduct a review.

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