Step 1: Educate client on what a QOF product is and whether they qualify by using the educational materials provided above, and/or speaking with either Matt or Andrew from CIM directly with the client. 

Step 2: Open a Non-Managed account at TD using the usual process through Fusion, using your Non-WRAP TBP Rep code. WWA/TD paperwork must include the following, all of which can be generated through Fusion and signed electronically:

Required Paperwork for Step 2:

1. TD Ameritrade Standard Account Application 
2. TD Alternative Investments Custody and Transaction Form
3. TD Move Money Authorization***
4. WWA Non-Managed Investment Advisory Agreement
5. WWA CIM Disclosures & Acknowledgements

*if your client already has a Non-Managed account open, that account can be used to house the CIM Opportunity Zone*

*you must not move forward with any Opportunity Zone investment direct at CIM without all the required paperwork listed above being on file first*

Step 3: Decide with the client what dollar amount ($150k minimum) and by what method the Opportunity Zone investment will be funded. Normally funds are wired into CIM directly from a client’s bank account and must be eligible capital gains only. Funding and delivering bank information must be included in the next step so it is important to decide this ahead of time. Reach out to CIM directly for assistance if needed.

*Funding an Opportunity Zone fund with actively Managed assets from an account at TD is more complicated in relation to eligible capital gains and paperwork. We recommend the source of funding be outside of TD. Reach out to WWA Ops with questions*

Step 4: Complete the CIM Subscription Agreement online. To do this, contact CIM directly to obtain log-in credentials for the icapital website and save these credentials. You must complete the agreement on behalf of the client while entering in responses the client provided, since the client will not have their own log-in credentials for the icapital site.

Required Paperwork for Step 4:

1. CIM Subscription Agreement

*The Non-Managed TD account number and Non-WRAP TBP rep code from step 2 above must be inserted on the CIM subscription agreement in order for the investment to flow through into TD*

Make sure that the subcription agreement is set up with CIM to send income distributions to the Custodian! This way, the quarterly 1-2% income can be charged against WWA monthly management fees and the client will not have to add cash to cover fees. Also, then we can help control if they want to take a cash withdrawal. If there is not enough cash from income distributions from the fund to cover management fees, the client will need to add separate cash to cover it. As a last resort, WWA staff will automatically initiate an incoming ACH from the bank account on file if needed.

For help completing the subscription agreement, contact CIM directly, or the icapital customer help line provided above.

Step 5: Download and save a copy of the completed CIM subscription agreement. Upload the document as an attachment into the Fusion ticket you previously created during step 2. WWA staff will then submit the subscription agreement to TD on your behalf and ensure all required paperwork is in good order with TD in preparation for the investment purchase. WWA staff will be in contact via the Fusion ticket with any NIGOs and general communication.

Step 6: Work with CIM directly and/or refer to the Key Dates PDF above for required paperwork deadlines, purchase close dates, and final steps. Once the initial purchase is made, the client will see their QOF reflected online in the Non-Managed account at TD the next time that CIM pushes out the balances to TD.

Many FAQs are answered within the CIM Disclosures and Acknowledgements document!

1. How to fill out the TD Alternative Investment document:
   • • Insert Non-Managed TD account number and Non-WRAP TBP rep code matching the info provided on the CIM subscription agreement.
     • Investment Advisor Firm Name: Wealth Watch Advisors
     • Primary Contact: *Skip* (this never needs to be filled out)
     • Section 1: Capital Call
       Section 2: *Skip*
       Section 3: No to all
       Section 4:
       • Investment Name: CIM Opportunity Zone Fund
       • Total Commitment Amount: (insert amount of initial purchase)
       • Current Capital Call due: $0 (zero) 
       • Standing Letter of Authorization: YES

1. WWA staff can assist with WWA and TD required paperwork and making sure everything is in good order for TD to custody the fund, but most other questions outside of this will be handled directly at CIM. They have a support staff dedicated to helping with enrollment on their end.
   
   
2. QOFs can only be held within taxable accounts, not retirement accounts.
   
   
3. QOFs can only be held within Non-Managed accounts under WWA. They may not be comingled within Managed accounts to limit the rate at which they’re billed, to protect against any potential trade errors, and to keep WWA Managed performance reports more clear and concise.
   
   
4. QOFs will be billed at the standard Non-Managed account fee schedule rate agreed upon by the Advisor and Client, with the usual 40bps minimum and a 100bps maximum. The difference between 40bps and 100bps is what the Advisor will earn.
   
   
5. Cash to purchase the QOF should be provided from an outside bank account from the client and is sent directly to CIM’s third party affiliates. The funding does not go through TD first. Funding this investment from an account at TD will complicate things more in relation to paperwork and determining eligible capital gains. Cash should be deposited into TD only if it is needed to cover fees.
   
   
6. The purchase of the investment takes place off-site at CIM’s third party holding company, and not at TD. The values are later pushed over to TD and TD becomes the official custodian, where TD will generate monthly statements and handle the usual client communication on the account.
   
   
7. QOF values at TD are updated 2-3 weeks after the initial purchase, and every 60 days after the end of each calendar quarter. The value that WWA, the Advisor, and the Client see at TD will remain static for months at a time and is not updating on a daily basis. Pushing values to TD is entirely dependent on CIM and the according to them this timeline is approximate.
   
   
8. WWA will bill the account monthly based on the values available at TD at the time of the billing cycle.
   
   
9. 1-2% income distributions will be sent to the account at TD on a quarterly basis *as long as the subscription agreement at CIM indicates to send cash to the custodian*. This is recommended to provide cash for covering most management fees. 
   
   
10. The cash from income distributions cannot be used to reinvest into the QOF fund, in other words there is no automatic reinvestment program.
    
    
11. If there is not enough cash in the account to cover fees from income distributions from the fund, or by cash that was added up front by the client, WWA staff will automatically initiate an incoming ACH from the bank account connected to the TD account to cover fees. This is why the client will be required to sign a Move Money Authorization form to connect a bank account of their choosing in the beginning. Not having cash available in the account for fees will lead to large cash debits that create a red flag for us at TD and will lead to compliance and billing problems later.