Periodic Distributions – non 72T

A client had a Periodic Distribution, but asked us to stop the distributions, so we did. Then, several months later, they ask us to restart the distributions again. Can we accept the rep of record’s email authorizing to restart the distributions or is there a rule saying whether we should ask for a new form and/or signature?



It would appear that if the procedure calls for a signed form to start initial periodic distributions, a new one should be required for each new series of distributions. Terminating the first series would effectively nullify the first form. This is a general statement, not knowing completely what all the possible functions of the signature are.



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