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 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 85 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, 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.