Compliance Agreement Since the Internet is readily accessible by clients from every state, holding yourself out as offering investment products and services over the Internet could be considered offering securities and advice to the residents of each state. As such, this could require that you be registered with every state. In order to avoid this costly measure, state regulators have established specific guidelines that, if followed, exempt you from state registration requirements as they relate to the use of the Internet. The design and approval process of these advisor Web sites already takes care of most of these requirements for you, but there are certain procedures that you must also understand and agree to follow. State regulations require that prior to having any subsequent direct follow-up with any member of the public that has visited your Web site, you must ensure that you are properly registered in that client's state. These advisor Web sites have been designed to require clients to enter their states when requesting information from you via email. When receiving any requests for information, you may only provide such if you are currently registered in the individual's state. Furthermore, if you receive any direct contact from any individual (whether by email, regular mail or phone) that did not come through the Web site's standard email form, and therefore, may not provide the individual's state, you must first determine the individual's state and ensure that you are currently registered in that state before providing any information on investment products or services. In short, you may not follow up with anyone in any state in which you are not registered. You should simply explain to them that you are only permitted to provide investment information to individuals in states where you are currently registered. Failure to do so could negate your exemption from state registration requirements, and you could be restricted from further use of the Internet and charged with offering securities in a state in which you are not registered. Effective January 31, 2006, all financial advisors who provide a comprehensive written financial plan must be registered as an investment advisor representative (IAR). This is pursuant to a specific provision in Rule 202(a)(11)-1 under the Advisor Act, which is commonly referred to as the "Merrill Lynch Rule." Site owners are required to read and follow the Raymond James online Privacy Policy. Should you have any questions regarding these policies and procedures, please contact your appropriate Compliance department. By selecting “Agree” below and submitting information requested in the following form, you agree to be charged the applicable amount for the type of Web site requested. This includes the cost of the website creation, monthly hosting, and monthly support package. Note: Only the website owner can accept the compliance agreement. The website owner must select the following check box before the website can be submitted. For questions or comments about this form please contact Web Services at ext. 75423 |
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