Sutro at SIFMA-CL (Day 2)

SALES TO SENIORS IS EMPHASIZED AT ANNUAL SIFMA CL CONFERENCE

Sales to Seniors is unquestionably the hot topic at the 40th Annual SIFMA CL Conference in Orlando. FINRA, the SEC, compliance professionals, in-house and outside counsel are highlighting and stressing the need for firms to focus on the propriety of their sales practices and adequacy of their supervisory procedures related to marketing, selling and communicating with senior clients.

The regulators remind the industry that there are no special rules for seniors. Rather, suitability standards, the firm’s sales and marketing policies and the firm’s written supervisory procedures should encompass all issues related to sales to seniors (FINRA Notice).

Some considerations when serving senior clients include:

· age
· life stage
· liquidity needs
· retirement plans
· diminished capacity
· heirs, fiduciaries and estate planning issues
· client sophistication and suitability of product
· commission versus fee-based arrangements

Firms should be surveying, testing and validating their supervisory policies and procedures to assure protection of senior clients. Firms should be training their sales forces and adopting best practices related to sales to seniors.