Client Facing Reports

Good Morning.

One of our IARs would like to use an excel spreadsheet report that lists all clients accounts, contributions, credits and withdrawals. It includes a beginning and ending balanca, a Year End $ change and Year End % change, as well as a Net Year End Change. This is not claiming performance, just change in account value. There would be appropriate disclosures.

Would you allow this? With our access to e-money and Morningstar Office, I don't see why we need a manual excel report, but I am wondering if there are any actual regulations against the report that I can reference.

Thank you.


  • Hi Stephanie,

    I don't see any prohibitions against its use but I agree it would make to provide this information other than manually.

    The disclosures needs to state where the information was derived from, that it is presumed to be correct and that:

    "Please consult the statements provided by your custodian for more complete information. In the event of any discrepancy, the custodian’s information shall prevail."


    Myles Edwards, Esq.
    General Counsel, Chief Compliance Officer & Chief Operating Officer
    Shufro, Rose & Co., LLC
    745 Fifth Avenue, 26th Floor
    New York, NY 10151-2600
    Direct (646) 517-1184
    Mobile (973) 650-4385
    Facsimile: (212) 754-5111

  • Hi Stephanie,

    I agree with Myles' position, and would add that if it is an absolute "must" for some reason, to require the advisor to include copies of the custodial statements where the numbers were derived from as attachments to the consolidated statement cover page. We have reporting software that does allow for advisors to input manual values for assets which we cannot pull in electronically, and in those situations we always require a copy of the actual statement displaying that value to be included as part of the client presentation package.


    Jennifer Tanck, Esq.
    Executive Vice President
    (813) 453-4659

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