October 17, 2007
I work for a financial company where we transfer in client accounts often. It is a very frustrating procedure waiting on the delivering firm to decide to ACATs over the clients holdings. However, the most frustrating part is waiting on residual holdings, such as cash from the sell of holdings that can not be held at the new firm. We have had to wait for weeks for the other company to transfer over cash, meanwhile the client has lost out on being able to invest the cash while the market moves up or down.
What stands out to me is that the mutual funds, stocks, cash, etc. belong to the client. If that client signs a statement indicating they want the funds transferred somewhere else action needs to be taken as soon as it is received. If some of the holdings have to be sold because they can not be held at the new firm, the cash should be pushed over as soon as it settles, not weeks later.
I support the proposed change in decreasing the number of days from the time the request to transfer is received and when action is required to be taken. I also ask you to look at revising the procedure for how long another company has for delivering residual funds/cash.