Ruling Review Notes

It's important to understand when to use information from the parent entity.
Specifically, whether information about the board of directors or corporate officers can be taken from the parent entity.

Individual Client Rights/Organization/Entity: The focus is on the specific entity under review, not solely relying on the parent entity's information.
Subsidiaries/Entities with Limited Public Information: If the entity is not widely known and public information is scarce: Internal documents may provide some information, but its correctness and freshness are uncertain.
Even if parent entity information exists, it may not be applicable or reliable for the specific subsidiary.

When working on funds (mutual, private, pension plans), there's heavy reliance on investment advisors.
Investment advisors and their corporate officers/directors are often responsible for the funds.
In such cases, confirm with the client whether these individuals are also officers/directors of the fund entity being reviewed.
Look for confirmation in prospectuses or other documents that state their responsibility for the entity.
Evidence or confirmation is needed to link parent entity officers/directors to the client entity.

Client Entity A has Parent Entity B.
There are individuals who appear as corporate officers/directors for both A and B.
However, it's unclear if they're acting in those roles for Client Entity A specifically.
Websites might not clearly state their roles for Client Entity A.
If there's any doubt or lack of clear evidence, reach out to the client for confirmation that those individuals are indeed acting as directors/officers for the client.

We can't use parent company information if it's unclear; we need to reach out for confirmation.
Write down information from the parent company and ask the client to confirm it.

Scenario 1: The entity is an existing client, and historical documents (previous reviews, onboarding) are available.
- If existing documents contain relevant information, take it as a reference.
- If the task requires refreshing/verifying information, but public sources don't provide it: Replay the existing information to the client and ask for confirmation of its current validity.
Scenario 2: No prior information is available.
- External documents are consulted, but no website for the client entity is found.
- The parent entity's website is available, showing corporate officers.
- If there's no indication that these officers also act for the client entity, leave the information blank.
- Information can't be transferred from the parent to the client entity without indication.
Gray Areas: If there's some indication (entity name mentioned on the parent's website) but it's not conclusive or clearly evidenced (minor details, nature of business mentioned): Replay this information to the client for confirmation.

Parent entity website mentions the client entity but doesn't explicitly state that its officers also act for the client entity.
Some minor details about the client entity are given, but board of directors/corporate officers for the client are not clearly listed or confirmed.

Consult emails and guidance for information, especially within the Goldman Sachs environment.
Ensure access to Goldman Sachs systems for case work, and address access issues with Lisa.
Remember email from Andy, sent to Lisa and Frankie, containing primary and secondary sources.

If an entity appears on FINRA, it's definitely a broker-dealer.
It can appear on both FINRA and the SEC website.
The FINRA BrokerCheck and the SEC's IAPD website are linked.
Sometimes, clicking on an entity in FINRA will redirect to the SEC site (IAPD), indicating regulation by the SEC, not FINRA.

Statuses like "failure to renew" or "terminated" on the SEC's IAPD indicate that the entity is no longer regulated.
Entities can be regulated at the state level (e.g., California, Texas) even if terminated at the SEC level.
Approved status is needed.

Registered Investment Advisors (RIA) and Registered Broker-Dealers (RBD) are common case types.
If there's an indication that the client is an RBD, classify it as such, taking precedence over RIA status.
Consider the guidance notes.

Everything is written in the guidance, but there are scenarios, jurisdictions, and classifications not fully covered.
If an entity is a broker-dealer, statuses will appear in FINRA.
If the entity is an investment advisor, they will be available on the SEC IAPD as a regulated entity.
If regulated status appear classity the entity as an investment advisor.

Multiple labels can be on a case. Refresh label on the entity name, verify and refresh label on tasks, etc.

Labels are a key part of conducting the ruling review.
Based on them, we know on what information to evidence on the task.
Based on them, we decide to confirm from the client.
Labels define whether we're meeting the requirements.

Labels are divided to four labels

Checks of the accounts: accounts icons

Check if the entity is with active accounts with Goldman Sachs to ensure we've active accounts or not
There will be multiple accounts with one client entity
We need at least one in active. otherwise is non trading stages, the entity will be off boarding because it doesn't make sense to conduct rolling review
Accounts will be active and special active for the process

Whether our identity is an active or inactive status or not or it's acquired by some other entity
Refer to the constitutional documents, like certificate of permission, incorporation, partnership or LLC agreement. Refer to companies registered as per country:
If the entity is on active status, then we proceed the task.
This is the second check whether our entity is in active status because whether account status will be first one,

There will be a data which can been flown from the existing ruling or pervious onboarding. e.g. Wells test Document ID
if the entity is incorporated in US and is a Delaware Registry, refresh: there could be appearing the name which proves that stays still existenced

First- Evidence of existing where we can utilize the existing document, on file document to complete the "evidence of existing task"
Second - SIP notification
Third- legal Structure
Fourth - Government ID

So we have multiple sources to identify and verify that but we are required to utilize this one from where we can identify signatories (only/HAC accounts:)

Data is present and needs to be refreshed
Applies to client onboarding roles to do those!
Three Option to refresh the entity, either publicly we obtain or the client is used to confirm or provide.
*Name