Jun. 6, 2024
Hello, I endorse the spirit and detail of this rule and hope it goes into force in a way that isn't too burdensome for financial advisors and RIAs. I had one question/concern and it regards KYC when it comes to an account held in living trust. When an acct titled in the name of a living trust is initially opened, an investor will sign, under penalty of perjury, a "Certification of Trust '' form that is also notarized. At that point, the identity of the trustor and the trustee of the trust may be verified. However - there is no way for an RIA to know if, an hour, a day, a month, or even years later, if the trust is amended. The trust could be amended to change the beneficiaries (potential terror organizations) and also the trustee or successor trustee could be amended (meaning the acting agent of the trust cannot be verified) and the firm would have no way of knowing. How does the SEC control for RIAs and other advisors maintain current on the trust in regards to amendments that would change the beneficiaries or trustees? Our company, illuminote, has initiated a digital trust registry that maintains digital and authentication protocols for a trust - meaning no changes can occur in the dark. The trustee of record is now able to be authenticated. If that trustee changes, the firm is notified. At that time, they can run an ID on that new trustee. Warmly, Matt _______________________________ Matt Everson Chief Commercial Officer | Global Sales illuminote