Crump

Interoffice Memorandum


To:
All Crump Teammates

Subject: Using Webex With Retail Clients or Institutional Investors (Essential Info for P.J. Robb Associated Persons and Registered Representatives)

Date: March 17, 2020


To better support and collaborate with our teammates, clients, and carriers who are working remotely, we are sharing additional guidance for use of Webex Tools by Associated Persons of P.J. Robb (which includes Registered Representatives).

In an effort to assist you in transitioning your retail client and institutional investors meetings from in-person meetings to virtual meetings, Crump’s Webex platform will provide you with the capability to schedule Webex Meetings.

Webex Meetings provide the following capabilities:

  1. Conference call capabilities
    P.J. Robb: There are no additional procedures for utilizing voice-only Webex conference call capabilities with retail clients or institutional investors, which is considered the same as any telephone call or conference call in the ordinary course.
  2. Sharing written communications
    P.J. Robb: FINRA Rule 2210: Communication with the public requires prior approval, review, and recordkeeping for written or electronic communications with the public. Therefore, any written materials involving a variable product or a security that are to be viewed on your computer screen during a Webex with a retail client or an institutional investor must be emailed prior to the Webex to ensure compliance with this rule. Please list “Webex” in the subject of the email.
  3. Chat, file transfer, or notes
    P.J. Robb: These capabilities are prohibited from use during Webex Meeting with retail clients or institutional investors.

It is the responsibility of associated persons of other firms to ensure that their Webex use complies with their broker-dealer’s guidelines.

Please reference the P.J. Robb Written Supervisory Policies and Procedures on the Crump Intranet and BB&T InSite, as necessary. If you have any questions, please discuss this with your registered principal or feel free to contact Linda Stump.

Note that Crump’s L.I.F.E. Education Group (LEG) will be sharing educational content for using Webex. For anyone needing to set up a Webex account, please review the instructions on the Crump Intranet > Technology > Teleconference/Webinar Accounts.

03.20 For internal use only.