Third Party Investment Services Agreement (TPISA)
A third party investment services agreement, or TPISA, is the contract between a financial institution and the broker-dealer or investment adviser that provides investment services to that institution's customers. It sets out how the program runs on the institution's premises: which services are offered, how customers are referred, how compensation is shared, who supervises the representatives, and how the program is disclosed to customers. It is not filed with a regulator. Both parties retain it.
- Who handles it
- The institution and the third party provider execute it and each retains a copy. Administering it falls mostly to the provider's compliance and operations teams, because most of its terms describe conduct that continues for the life of the program rather than a one-time act.
- Filed through
- Retained by the firm
- Applies to
- Broker-dealer, Dually registered, SEC-registered RIA
What the form asks for
- Scope of the investment services offered through the institution
- Use of premises and branding, and how the program is kept distinct from the institution's own products
- Referral arrangements and how customers reach the program
- Compensation and revenue sharing, and how each is calculated and settled
- Supervision of representatives, and which party holds which responsibility
- Customer disclosure arrangements for non deposit investment products
- Recordkeeping, audit rights, and information sharing between the parties
- Term, termination, and the treatment of customer accounts at the end
The work behind the filing
Turn ongoing commitments into evidence you already hold
The agreement commits both sides to things that happen continuously: disclosures given, referrals tracked, supervision performed, compensation calculated a stated way. The proof of each sits in a different system, and often on a different side of the relationship, so it gets assembled by hand when someone asks. Caddi can assemble and maintain that record as the work happens.
Reconcile the revenue share against what the contract says
The compensation terms live in a signed document and the settlement happens in a spreadsheet built by someone who read that document once. The two drift, usually quietly and usually in one direction. Caddi can extract the terms from the executed agreement and compare them against what was actually calculated and paid, period by period.
Keep each program's paperwork straight
A provider working with several institutions runs several programs, each with its own branding, disclosures, and packet, and often the same representatives across more than one. Picking the right version is a memory test today. Caddi can produce the paperwork that belongs to the program the customer is actually in.
Questions
What is a third party investment services agreement (TPISA)?
It is the contract between a financial institution and the broker-dealer or investment adviser that provides investment services to the institution's customers, covering the services offered, referrals, compensation, supervision, disclosure, recordkeeping, and how the program ends.
Is a TPISA filed with a regulator?
No. It is executed between the two parties and retained by both. FINRA Rule 3160 addresses arrangements where a member firm operates on the premises of a financial institution, and it is the rule the agreement is usually written against.
Why are TPISA obligations hard to evidence?
Because they are continuous rather than periodic, and because the record is split across two organizations that run separate systems. Neither side holds the whole picture, so producing it means gathering from both, which is why it happens only when someone asks.
Does Caddi file this form for me?
No. Caddi does not submit filings to IARD, FINRA Gateway, EDGAR, or any regulator, and it is not a substitute for your compliance program or your CCO. Caddi automates the work around the filing: gathering the underlying data out of your portfolio, CRM, and document systems, reconciling it against the prior filing, flagging what changed, and evidencing delivery. A human still reviews and files.
Related forms
The filing is the easy part
Caddi does not file forms. It runs the work around them: pulling the underlying data out of your portfolio, CRM, and document systems, reconciling it against the prior filing, and evidencing delivery. See it run on your own stack.
See the compliance specialistThis page describes what the form is and the work it creates. For requirements, deadlines, and whether any of it applies to your firm, see FINRA Rule 3160: Networking Arrangements Between Members and Financial Institutions.