I'm a broker-dealer employee thinking of FINRA rule 3210. Can Rocket Dollar give me and my compliance team account statements?

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All Rocket Dollar customers are LLC managers or plan trustees of the Self-Directed IRA or Solo 401(k). The investor is responsible for providing all records to their own compliance teams and Rocket Dollar cannot assist.

  • The purpose of Rule 3210 is to govern accounts opened or established by advisors and brokers at firms other than the member firm where they are employed or registered. Accounts that financial advisors and brokers have with their employers are easily monitored. It also puts conditions on accounts opened and maintained by anyone associated with members. Associated persons include people who are related to the employee such as spouses, children, and other family members.

    The new rule focuses on external accounts with other broker-dealer firms. It requires all licensed employees to declare investment accounts held with other financial institutions. Under the new rule, advisors and brokers are also required to notify their employer in writing of their intent to open a new account as well as declare all accounts where they have a financial or beneficial interest.

    All employees must now declare their intent and obtain prior written consent from their employer if they wish to open or maintain an investment account at any other financial institution where securities transactions take place. This must also be done if the employee has a beneficial interest in the opening and maintenance of the account.

    Member firms can request that employees provide copies of account documentation, such as transaction confirmations and account statements, at any time. Therefore, advisors and brokers should keep records of all account information and transactions.

    Source: Investopedia

  • Many Rocket Dollar customers open and purchase what is known in the Self-Directed IRA industry as a Direct Custody IRA. This IRA and the client works closely with a custodian partner to deal review each non-publically traded investment before a client is allowed to invest in it. This review is mainly to note IRS rules, and check for prohibited transactions. The Direct Custody IRA custodian has a clear record of every single investment the client has made. We can work to deliver you a statement of your account in this format if needed. If there is an additional rule 3210 compliance requirement, you must work with your current employer and firm holding your financial licenses. Other Rocket Dollar customers use retirement accounts with "checkbook control." This is present in our IRA LLC and Solo 401(k) Trust account. This means the investor takes on great responsibility for their own investments, deal review, and compliance. Rocket Dollar's custodian partner assists in holding an entity for all IRA customers, an IRA LLC, and then the investor, as manager of the IRA LLC, picks investments and signs paperwork for investments in the name of the LLC. 

    Because of the wide variety of alternative investments, some investments Rocket Dollar customers might pursue in their retirement accounts might have extensive documentation and statements (such as a venture capital fund, pre-IPO stock, REIT, precious metals account, or hedge fund) and some might have little to none at all (private loans, individual real estate properties, small private businesses, cryptocurrency).

    Rocket Dollar does not currently provide statements or authenticity of customers' investments inside of an IRA LLC. Managers of IRA LLCs report the fair market value of their investments to Rocket Dollar and our custodian, and our investment tracker is self-reported by each investor. While we are working to provide more statement tools for our customers to display current account values, the IRA LLC will always be fundamentally disconnected from formal statements expected in a direct custody relationship. Rocket Dollar is looking at ways to improve statements, but know that many IRA LLC investments are self-reported. If you would like to know more, please check out the article comparing our two account types.

  • It is up to you and your firm's compliance team. If you notify your broker-dealer that you intend to open a Rocket Dollar account, it could be wise to also notify them of exactly what you plan to invest in. Many Rocket Dollar customers can ask their investment issuers for extensive investment documentation for their investments in their IRA LLC or Solo 401(k) Trust, but exact statements and documentation can not be provided by Rocket Dollar itself.

  • No. Rocket Dollar Direct Custody IRA accounts do not have the capability to live trade public securities at this time.

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