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A shared business number allows an advisor and an assistant to respond to client calls and texts through the same line.
On the other hand, shared access raises concerns about who can read client information, respond to instructions, and review the resulting conversations.
Your firm needs to determine those responsibilities before granting access. An assistant answering a scheduling question, for instance, has a different role from an advisor discussing an investment recommendation, even when both use the same number.
So, before introducing a shared line, consider how your firm will manage permissions, supervise communication, and preserve records.
The article discusses these compliance questions and explains how your firm can help you resolve them with iPlum's Shared Line.
Let's dive right into the compliance questions.
Table of Contents
1. Who should have access to your firm's shared business number?
2. How will your firm supervise conversations when several employees use the same number?
3. How will your firm supervise conversations when several employees use the same number?
4. How will your firm record, retain, and retrieve shared-number communications?
6. How can your firm introduce a shared business number with iPlum?
Who should have access to your firm's shared business number?
Access to a shared number should correspond to an employee's assigned duties.
An assistant responsible for appointments needs different permissions from an advisor discussing account recommendations or a principal reviewing correspondence.
So, before granting access, determine which client communications the employee needs to receive and what they're authorized to do with them.
Here’s how to go about it:
Assign access according to employee responsibilities
Define the permitted activities for advisors, assistants, and administrators using the number. Your firm should specify:
- Administrative enquiries: Who can confirm appointments, acknowledge messages, and arrange return calls?
- Investment questions: Who can discuss recommendations and respond to questions about a client's portfolio?
- Client instructions: Who can receive an instruction, who must review it, and who's authorized to act.
- Complaints: Who must refer a complaint for supervisory review?
With iPlum's Shared Line, administrators can select the users who can access a business number. Authorized colleagues can then communicate through that number from their own devices.
Decide which services employees can access
Permission to answer calls shouldn't automatically grant access to all client correspondence. A colleague assigned to telephone enquiries may need call access, while an assistant managing written follow-up also needs text access.
iPlum allows administrators to configure sharing for calls, texts, contacts, fax, and voicemail. Select the services required for the employee's duties, based on the client information available to them.
Also, distinguish permission to communicate from permission to administer accounts. An employee who answers client calls doesn't necessarily need authority to change another user's settings.
Revise permissions when responsibilities change
Temporary assignments and employee departures require corresponding changes to access. If a colleague gains access during an advisor's absence, specify when that access ends and review permissions upon the advisor's return.
Likewise, withdraw shared-line access when an employee leaves or moves into a role that no longer requires it. Your administrator should review both the shared number and the services available to that user.
On that note, the iPlum portal provides the settings for managing shared users and permissions. It allows your firm to assign responsibility for updating those settings as personnel responsibilities change.
How will your firm supervise conversations when several employees use the same number?
A shared number gives clients a consistent point of contact, but several employees can participate in the conversation.
Your firm, therefore, needs to determine who's responsible for responding and how supervisors will review those exchanges.
The distinction is particularly important when a routine enquiry develops into a complaint, an investment question, or an instruction involving client funds.
Here’s what you need to do:
Assign responsibility for replies and referrals
Specify who monitors incoming messages and who takes responsibility when a conversation requires an advisor's attention.
An employee acknowledging a message should know whom to notify and how to confirm the referral reached its intended recipient.
Your procedures should address:
- Initial responses: Who acknowledges the enquiry and determines who should respond?
- Referrals: Which questions require an advisor or supervisor?
- Pending replies: Who checks that the client received a response?
- Employee identification: How should employees identify themselves when communicating through the shared number?
For instance, an assistant can acknowledge a request to discuss a withdrawal and notify the advisor. However, the acknowledgement shouldn't imply the firm has approved or processed the request.
Also, employees should identify themselves when joining a conversation. A client texting an advisor's number shouldn't have to infer who's replying.
Review earlier messages before continuing the conversation
Before responding, read the preceding exchange to determine what the client requested, what a colleague said, and which questions remain unresolved.
Otherwise, an advisor could repeat a request the assistant already made or provide an answer based on incomplete information.
iPlum's shared message history allows authorized users to read the text thread associated with the shared number. That way, an advisor taking over a discussion can therefore consult the earlier exchange before replying.
Separate supervisory review from daily responses
Reading a thread to answer a client serves a different purpose from reviewing correspondence for compliance. Your firm should assign supervisory responsibility separately, even when the supervisor also has access to the shared number.
For FINRA member firms, Rule 3110 requires procedures for reviewing relevant incoming and outgoing correspondence. A registered principal must conduct the required reviews and document them electronically or on paper.
The review should address the substance of the conversation, including client instructions, complaints, and responses requiring further examination. It should also document any follow-up and its resolution.
iPlum's call recording and text archiving provide records your firm can examine during that process. The reviewer must then assess the communication and document the review through your firm's supervisory procedures.
How will your firm supervise conversations when several employees use the same number?
A shared number gives clients a consistent point of contact, but several employees can participate in the conversation.
Your firm, therefore, needs to determine who's responsible for responding and how supervisors will review those exchanges.
The distinction is particularly important when a routine enquiry develops into a complaint, an investment question, or an instruction involving client funds.
Here’s what you need to do:
Assign responsibility for replies and referrals
Specify who monitors incoming messages and who takes responsibility when a conversation requires an advisor's attention.
An employee acknowledging a message should know whom to notify and how to confirm the referral reached its intended recipient.
Your procedures should address:
- Initial responses: Who acknowledges the enquiry and determines who should respond?
- Referrals: Which questions require an advisor or supervisor?
- Pending replies: Who checks that the client received a response?
- Employee identification: How should employees identify themselves when communicating through the shared number?
For instance, an assistant can acknowledge a request to discuss a withdrawal and notify the advisor. However, the acknowledgement shouldn't imply the firm has approved or processed the request.
Also, employees should identify themselves when joining a conversation. A client texting an advisor's number shouldn't have to infer who's replying.
Review earlier messages before continuing the conversation
Before responding, read the preceding exchange to determine what the client requested, what a colleague said, and which questions remain unresolved.
Otherwise, an advisor could repeat a request the assistant already made or provide an answer based on incomplete information.
iPlum's shared message history allows authorized users to read the text thread associated with the shared number. That way, an advisor taking over a discussion can therefore consult the earlier exchange before replying.
Separate supervisory review from daily responses
Reading a thread to answer a client serves a different purpose from reviewing correspondence for compliance. Your firm should assign supervisory responsibility separately, even when the supervisor also has access to the shared number.
For FINRA member firms, Rule 3110 requires procedures for reviewing relevant incoming and outgoing correspondence. A registered principal must conduct the required reviews and document them electronically or on paper.
The review should address the substance of the conversation, including client instructions, complaints, and responses requiring further examination. It should also document any follow-up and its resolution.
iPlum's call recording and text archiving provide records your firm can examine during that process. The reviewer must then assess the communication and document the review through your firm's supervisory procedures.
How will your firm record, retain, and retrieve shared-number communications?
A client's conversation can pass from an assistant to an advisor and continue through calls and texts. If the client later disputes an instruction, your firm needs records of the relevant exchanges, regardless of which employee responded.
So, before employees begin using the shared number, determine which communications your firm will preserve, how long it will retain them, and who can retrieve them.
Here’s what you need to do:
Set recording and notification requirements for the shared number
Determine whether your firm must record calls under an applicable rule or chooses to record them under its internal policies.
Once your firm adopts recording, apply its procedures consistently to all employees who use the shared number. An assistant answering an incoming call and an advisor returning it should follow the same notification requirements.
Your procedures should address:
- Recording settings: Which business lines require automatic recording?
- Caller notification: What notice and consent does the applicable law require?
- Client objections: What should an employee do if a client objects to recording?
- Verification: Who checks whether incoming and outgoing calls produce retrievable recordings?
iPlum provides automatic recording for incoming and outgoing calls, together with a standard recording announcement. Your firm can use these functions as part of its recording procedures, with notification and consent requirements determined for the relevant jurisdictions.
Choose retention periods for the records your firm creates
Shared access and record retention serve different purposes.
Employees consult a message thread to continue a discussion. Your firm preserves the underlying correspondence so it remains available for later review.
Determine the required retention period according to your firm’s registration, the record category, and applicable obligations. Also, account for records subject to a complaint, investigation, or preservation hold before authorizing deletion.
With iPlum, you can get up to 10 years of call recording and text archiving on the Enterprise plan.
In addition, iPlum offers WORM storage for archived communication records. For starters, WORM means write once, read many, and addresses protection against rewriting or erasing stored records
Retrieve records for reviews and preserve them before cancellation
A reviewer investigating a disputed instruction needs the relevant exchange, including earlier messages that explain its context. A selected screenshot or an employee's recollection won't necessarily provide the full sequence.
iPlum allows authorized users to download text logs as CSV files.
Reviewers can also play call recordings and download audio through the portal. A recorded discussion can then be examined alongside the written exchange when assessing what the client requested and how employees responded.
Frequently asked questions
Can an advisor and an assistant use the same iPlum number on separate phones?
Yes. Authorized users can make and receive calls, send texts, and read shared message histories from their own devices. Administrators determine which services they can access.
Does sharing a business number authorize an assistant to give investment advice?
No. Access to the number doesn’t authorize investment advice. An assistant’s permitted activities depend on their role, applicable registration requirements, and your firm’s policies.
Does FINRA require all financial advisors to record every call?
No. FINRA Rule 3170 applies to firms meeting specific criteria. Your firm must determine whether recording obligations apply to its business and which calls must be recorded.
Does a shared text history replace a communication archive?
No. Shared history allows colleagues to review conversations during daily communication. An archive preserves records for the required retention period and subsequent supervisory, examination, or dispute review.
Which iPlum subscriptions do shared-line users need?
All participating users need an active Professional or Enterprise subscription. Enterprise provides automatic call recording and ten-year call and text archiving. The professional provides one-year text archiving.
How can your firm introduce a shared business number with iPlum?
Your clients should be able to contact your firm even when their advisor is unavailable.
A shared business number allows authorized colleagues to respond, but your procedures must define their responsibilities.
With iPlum, you can assign shared-line access, select the services employees use, and provide colleagues with the conversation history they need for follow-up. The Enterprise plan also provides recording and archiving for subsequent review.
Before granting access, decide who will answer enquiries, refer client instructions, and review correspondence. Then configure the number accordingly.
Click the link below to sign up for iPlum and give your advisors and assistants a shared business number for client communication today.
