Let’s start with the basics of KICS reporting and Broker Import requirements.
Our regulators require that we have a system of quality control in place
that provides reasonable assurance that the firm and its employees do not
lack independence. Specifically, the SEC rules require accounting firms to
have an automated tracking system for investments for our partners
and managerial employees.
Here at KPMG, that system is KICS. Therefore, we all have a responsibility
to maintain an accurate KICS account, as it is an important
element of our system of quality control.
Investments that must be reported in KICS include those that you or
your immediate family members (which include your spouse or spousal
equivalent, and dependents) hold or control, with the exception of investments
held in KPMG-US sponsored plans. Independence applies to a wide
range of investments including those shown here.
Be sure to also consider the types of investments that are often
overlooked when it comes to personal independence such as:
investments held through a variable life or annuity contract,
individual investments within a non-diversified fund that equal
20% or more of the fund’s total investments,
indirect investments, for example, investments held in a partnership
where you are a limited partner without control,
that are material to your net worth, or
investments held in non-KPMG employee benefit plans.
Independence rules apply to these investments and they must be
reported in your KICS account within 14 days of acquisition.
The KICS Broker Import Program facilitates compliance with the firm’s
personal investment reporting policies by automatically updating KICS
with the investments held in activated accounts.
All brokerage accounts that you or your immediate family members
hold (including those held through investing apps) must be with
one of the over 90 brokers that participates in KICS Broker Import.
Each account must be enrolled and activated for KICS Broker Import
within 14 days of opening the account. Remember to enroll and activate:
each individual account with the same brokerage firm,
accounts that have a zero balance, and
new accounts that are opened as a result of changing
brokers or brokerage firms.
Be sure to always check the restriction status of potential investments
before you make any changes to your portfolio. KICS Broker Import
does not block or prevent trades in restricted investments.
In addition to investments, any loans held, co-signed or guaranteed
by you and your immediate family members must be manually
reported in your KICS account. Independence rules apply
to a wide range of loans, including those shown here.
It is important to consider all loans and ability to borrow against
assets that you and your immediate family members have, including:
consumer and point-of-sale loans, for example, for appliances or furniture,
home equity lines of credit on primary and non-primary residences,
even if unused,
brokerage account and digital wallet margin loan features, even if unused, and
overdraft protection on bank accounts not tied to a savings account
or credit card, even if unused.
Each individual loan must be reported in KICS within 14 days of closing
on the loan or obtaining a line of credit or margin loan feature.
Loans must be reported by the name of the lender
(not the loan servicer, which may be a different entity).
Make sure you confirm the name of the lender and update KICS accordingly.
Set a monthly reminder to review your KICS account to help ensure
it’s up to date. If you discover a potential violation, report it to
Risk Management - Independence using the
Independence Inquiry Submission Form.