The Bulk Transfer process is broken down into four stages:
- Preparation - Firms begin preparation prior to a bulk transfer scenario. This includes identifying information detailed in the Broker/Dealer Profile and tailored communication templates.
- Pre-Transfer - As part of a commercial agreement, a receiving firm will agree to acquire customer accounts and assets from a sending firm. Both will begin pre-transfer activities including implementation of governance framework, developing daily conversations with relevant regulators, coordination of stakeholder communications, unencumbering of customer assets, beginning of transfer execution activities, and sending standardized files to facilitate the transfer.
- Transfer - During transfer of customer accounts and assets, both firms will continue to execute their respective transfer plans according to their respective governance frameworks. Firms will regularly
communicate with regulators to ensure on-going compliance, execute remaining transfer activities and exchange any remaining standardized files.
- Post-Transfer - Following the transfer of customer accounts and assets, the receiving firm must continue working with regulators to ensure compliance with relevant rules, and also continue to exchange optional standardized files to supplement any additional asset transfers.
Preparation can and should occur well in advance of a bulk transfer. As outlined in the Bulk Transfer Playbook, specific asset transfer methods may vary depending on the asset type.