“Compliance and You”

This presentation is for Producer use only

Non-Registered Agents, Registered Representatives and IAR’s all have have compliance rules to follow and high standards of ethics to maintain.

Field Guide to Compliance and Supervision: This guide is intended for use by Penn Mutual Producers that are Registered

Representatives of HTK. Penn Mutual’s Producers Guide to Market Conduct: This guide is intended for use by Penn Mutual Producers that are NOT registered

representatives of HTK.

IAR Compliance and Supervision Guidelines (OCT 2011)This guide is intended for use by Investment Advisor Representatives (IAR's) of HTK

NOTE: You have each been e-mailed the appropriate manual to place on your desktop for easy reference and access.

HTK Mandatory Firm Element Due Oct 31.◦ Annual Compliance Meeting ◦ Annual Compliance Questionnaire (Pay CLOSE

ATTENTION)◦ Mandatory Courses◦ Access via RegEd.com

User ID = Your HTK email (i.e., jsmith@htk.com) Password = Last Four Digits of Your SS# Company Code = HTK

Weekly Correspondence and e-mail Review

E-mail and Secure EMAIL- Encrypted *

Gifts & Non-Cash Compensation*

Outside Business Activities & DBA’s

Frequent Issues I find When Reviewing ClientFiles*

* There are Rules for non-registered producers as well as Registered Representatives and IAR’s.

Weekly Submission of Outgoing and Incoming Correspondence for Securities related products(In-House & Detached Reps)

H614: Business Transmittal Procedures for Securities related checks ,Stock Certificates, and Bond Certificates.

Best practice for logging and rules for procedures for non-securities related checks.*

E-Mails are correspondence*: E-Mail Review*There are Rules for non-registered producers as well as

Registered Representatives and IAR’s.

Producer ResponsibilityAll rules pertaining to written correspondence and standards of conduct

found

in your Compliance and Supervision Manuals apply to email as well.

All Producers are to use their approved Penn/HTK email address with potential clients and clients and business purposes.

Producers are encouraged to use business email for business purposes only and are reminded that all email sent from a company email address is subject to review and archiving regardless of it being personal in content.

Registered Producers are prohibited from accepting security transaction instructions(e.g., buy or sell orders, funds transfer requests) via email

Producers are prohibited from sending any type of unsolicited electronic mail messages, or “spam,” to anyone with whom they do not have an existing business or personal relationship.

This also includes soliciting or recommending the sale of any securities, insurance, or other product through postings to electronic discussion groups

EMAILS containing NONPUBLIC information, anything other than what you will find in a phone book (Name, Address, and Phone number) MUST be encrypted!

You are receiving a copy of the encryption guide today which will show you how to send emails containing sensitive non public information. ( sending a [SECURE] e-mail)

Pre-approval (Non-Cash Comp)& Post Review (Gifts & Entertainment)*

Completed H9018 Form & Log

FINRA

*There are Rules for non-registered producers as well as Registered Representatives and IAR’s.

What is an OBA? When do you add an OBA into REGED

for approval?What is a DBA?When do you need to add a DBA?Is being part of or raising money for a

non-profit organization an OBA?Keep Your U-4 Current via RegEd.com

You have each received a copy of: HTK/PML producer client file Guidelines

What “Should Not” be included in your client files:1. Private client medical information other than what was completed on

application. (i.e.: MD exams, APS, EKG, lab results)2. Original life insurance policies or annuity contracts3. Original client legal or financial documents (i.e.: trusts, wills, etc.)4. Original securities correspondence or complaints received

(all originals are to be given to Field Manager/IPS Team) 5. Any signed blank or incomplete forms!

Make Sure Producer use only documents are marked as such.(i.e.: illustrations with highlights or markings, summaries prepared for your use only, product or research materials which are not approved for client use.)