Issue link: http://clhia.uberflip.com/i/845971
business and incorporate this information into the review. The primary distribution firm would also share with those other firms any practice review concerns it finds. Secondary distribution firms In addition to their existing oversight responsibilities as a distribution firm, secondary distribution firms would have new commitments, including being required to: • inform and express any concerns about advisors to the advisor's primary distribution firm; • share data to support random practice reviews as requested by primary distribution firms; • cooperate, as needed, in investigations by primary distribution firms; and • take into account any review findings or concerns raised by a primary distribution firm. Insurers Insurers accepting business directly from independent advisors today would need to be licensed distribution firms under this approach so that an independent agent could designate an insurer's distribution firm as his or her primary distribution firm. 4 | Accountability Distribution firms should be accountable for the conduct of advisors placing business through them. Where an advisor is attached to multiple firms, each of these would retain responsibility for oversight of activity related to it. In addition, the new responsibilities attached to primary and secondary distribution firms would ensure that information is shared effectively for the purposes of practice reviews and concerns about advisor conduct. Insurers would also continue to have legislative and regulatory oversight responsibilities. However, within the context of a regulatory licensing regime, there would be a clear and consistent accountability role for distribution firms. Attached as Appendix I is a visual overview of how this enhanced oversight might look. 5