Adding a Trusted Contact Person (TCP)

Effective February 5, 2018, FINRA rule 4512

requires firms to allow customers to name a trusted contact person (TCP) and provide their contact information upon account opening. The customer can name a person at the advisor firm as a trusted contact person (TCP). Adding a TCP is optional; however, the advisor is required to make it available. Customers are encouraged to add a TCP, but are not required to do so. This important rule is designed to help prevent exploitation of the elderly, but natural person customers of any age can add a TCP.

The rule also requires, at the time of account opening, disclosure to the customer that Spire & the preferred Custodian is authorized to contact the TCP and disclose information about the customer's account to address possible financial exploitation and to confirm the specifics of the customer's current contact information, health status, or the identity of any legal guardian, executor, trustee or holder of a power of attorney. A TCP has no authority on the account, and being named a TCP does not give an individual access to the account or account statements or confirms. A TCP must be 18 years of age or older. The customer, by submitting the request, is affirming that the TCP is of age. No CIP requirements exist for TCPs; and the TCP's date of birth and social security number are not requested on the form.

Contact your preferred Custodian for supplemental documents to add a TCP to accounts; Spire has updated the Spire forms to accommodate for the TCP intake information. All advisors should be having discussions with client(s) regarding the reason for naming a trusted contact and be sure that the paperwork is properly documented along with supplemental documents. Reach out to Spire Operations for additional information.

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