PREPARING FOR THE NEW
COST BASIS REGULATIONS
How the changes will affect your firm and
what you can do now to get ready
PREPARING FOR THE NEW COST BASIS REGULATIONS
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EXECUTIVE SUMMARY
EXECUTIVE SUMMARY
The Emergency Economic Stabilization Act of 2008 included
new tax-reporting requirements that will dramatically change the
way independent registered investment advisors (RIAs) and their
clients think about cost basis. For the first time, brokers will report
the adjusted cost basis of sold securities to the IRS. The new
requirements are designed to help capture accurate reporting of
investors’ gains and losses at tax time.
As the requirements are phased in over the next few years, the
transition will cause some confusion. Complying with the new rules
will take planning and effort by industry participants, but in the long
run it will make tax preparation easier for investors.
Under the new-tax reporting requirements, brokers, transfer agents
and other reporting entities will bear the burden of compliance.
Most advisory firms, however, will nonetheless also experience
significant changes to their daily workflow. Firms that do not act
now—to prepare their back offices, manage clients’ concerns and
expectations, and reinforce the value of their services—might find
themselves unequipped to meet their clients’ needs and might
overlook potential opportunities.
2
THE LEGISLATION
Overview of Changes
4
KEY CHANGES
6
THREE STEPS TO TAKE NOW
Step 1: Create a Proactive
Communication Plan
Step 2: Anticipate Clients’ Needs
Step 3: Evaluate the Legislation’s Impact
on Your Back Office
12
OPPORTUNITIES
Build Loyalty
Consolidate Clients’ Assets
Offer Tax-Efficient
Investment Strategies
14
CONCLUSION
15
APPENDICES
1
PREPARING FOR THE NEW COST BASIS REGULATIONS
THE LEGISLATION
Currently, many brokers report cost basis information to clients of advisors as a value-added
service—but that is about to change.
“The new cost basis legislation will affect all
Overview of Changes
clients receiving Forms 1099-B. Advisors who
Brokers, custodians, transfer agents and other reporting entities
(collectively referred to as “brokers” for purposes of this paper) will
be required to report the adjusted cost basis of sold securities,
including whether the gain or loss is short- or long-term, to the IRS
and your clients on Form 1099-B. The requirements will be phased in
over three years, starting in 2011. Brokers will face significant
penalties for noncompliance, errors and late reporting.
help their clients successfully transition to the
new cost basis reporting regime will surely
enhance the client relationship.”
—Deanna Flores, Principal, KPMG LLP
The new tax reporting requirements represent a significant shift in the
way advisors approach cost basis reporting:
•Brokers will become an important source of cost basis information
provided to the IRS for securities covered under the legislation.
Advisory firms that track and report cost basis data to clients will
need to ensure that their reports match the data sent by brokers.
•For tax-sensitive investing, firms will need to consider the
tax consequences of a trade at the time of trade. Cost basis
methodology cannot be changed after the trade settles.
2
THE LEGISLATION
COVERED AND UNCOVERED SECURITIES
The legislation will roll out in three phases, as listed in the chart below. Covered securities are those
acquired on or after the applicable dates outlined by the legislation. Securities acquired by clients before
these dates are uncovered by the legislation. Brokers are not required to report cost basis on uncovered
securities. Taxpayers are responsible for accurate reporting of cost basis on covered and uncovered
securities to the IRS on their tax returns.
Covered Securities
Uncovered Securities
Broker vs.
Taxpayer
Responsibility
Brokers will report cost basis to IRS and Taxpayer will report cost basis
to IRS.
taxpayer on Form 1099-B. Taxpayer will
use Form 1099-B data in preparing their
tax return filing for 2011 and following
years.
Equities*
Acquired on or after Jan. 1, 2011
Acquired prior to Jan. 1, 2011
Mutual funds, dividend
reinvestment plan (DRIP)
shares and ETFs**
Acquired on or after Jan. 1, 2012
Acquired prior to Jan. 1, 2012
Other specified securities,
including fixed income and
options***
Acquired on or after Jan. 1, 2013
Acquired prior to Jan. 1, 2013
*Equities include corporate stock (other than stock in a regulated investment company [RIC] or stock acquired in connection with a dividend reinvestment
plan [DRIP]). Internal Revenue Code section 6045(g)(3)(C)(i) provides that the applicable date is January 1, 2011.
**For stock in a RIC (RIC stock) or stock acquired in connections with a DRIP (DRIP stock), section 6045(g)(3)(C)(ii) provides that the applicable date is
January 1, 2012.
*** For any other specified securities, section 6045(g)(3)(C)(iii) provides that the applicable date is January 1, 2013, or a later date to be determined in
the future. The reporting rules related to options transactions apply only to options granted or acquired on or after January 1, 2013, as provided in section
6045(h)(3).
3
PREPARING FOR THE NEW COST BASIS REGULATIONS
KEY CHANGES
The legislation will roll out over three years, affecting equities in 2011; mutual funds, ETFs
and DRIP shares in 2012; and other securities such as fixed income and options in 2013.
Here are some key changes you will begin to see starting in 2011.
“A trade date, automated lot-level solution
for sending cost basis information with
transactions to our custodians is critical not
only today but also to support our firm’s
growth requirements.”
—Mark Riley, The Milestone Group
Cost basis default method. The legislation requires brokers to
calculate gain/loss by using the first-in, first-out (FIFO) method as a
default on sold securities that are not eligible for the average cost
method. The average cost method may be applied as a default for
mutual funds, but even if it is applied, lots are to be sold in a first-in,
first-out manner.
For any position not using average cost, advisors and their clients
can choose lots using the specific identification method. This can be
done either at the time of trade or through a standing order (e.g.,
using high cost as a default method). Each broker may offer different
lot selection choices—check with yours to find out which are
available to you.
Specified lot decisions must be made before the trade settles.
If you wish to specify a particular lot to sell, or to change the cost
basis method for a sale, you will be able to do so only until the
settlement date of the trade. Once the trade settles, the method
used will be final.
4
KEY CHANGES
Transfer of cost basis information. The legislation specifies that
brokers must provide a transfer statement when transferring assets
to another broker. Transfer statements for covered securities must
include the transfer date, security identifier, acquisition date,
covered and uncovered status, cost basis and holding period. For
RIAs, receipt of the transfer statement will be a timesaver. However,
if a security is transferred between institutions without that transfer
statement, it will be considered to be uncovered at the time of
receipt. Securities can become covered once the appropriate cost
basis information is provided.
Gifted and inherited shares transferred between accounts. These
must be identified, and applicable accounting rules must be applied
to the gain/loss. For gifted shares, this includes capturing the date
of the gift and the donor’s adjusted cost basis and the fair market
value (FMV) of the shares on the date of the gift. If, when the gift is
made, the donor’s adjusted basis exceeds the FMV, special rules
apply that limit the loss the gift recipient can claim when the shares
are sold. Inherited shares will be uncovered by the legislation until
instructions from the estate executor are received on how to adjust
basis. The broker is required to make one attempt to obtain
COST BASIS METHODS
As of January 1, 2011, many
brokers will default to using the
first-in, first-out (FIFO) method to
determine the adjusted basis and
gain/loss of equities, unless you
notify the broker that your client
wishes to apply a different
permitted method at the time of
trade. Depending on your broker,
the following specified lot choices
may also be available for equity
trades and determing taxable gains:
• Last-in, first-out (LIFO)
• High cost
• Low cost
applicable instructions from the estate executor.
Tracking and reporting on wash sales. The new law requires
brokers to report loss deferrals and other adjustments on Form
1099-B. However, brokers are required only to analyze identical
securities within a single account to determine if a wash sale has
occurred. Only identical securities are subject to wash sale deferral
for purposes of cost basis reporting. Clients are still obligated to
apply the wash sale rules across all of their accounts when
preparing their tax returns.
5
PREPARING FOR THE NEW COST BASIS REGULATIONS
THREE STEPS TO TAKE NOW
Brokers are moving quickly to comply with the legislation, but RIA firms must also take
action. Although your clients won’t receive their new 1099-Bs until early 2012, now is
the time to start planning for changes to streamline the transition for your firm and to
help your clients understand the new rules. Preparing for the effects of the legislation—in
particular, determining how it may impact your clients and your back office—can help
improve your clients’ experience and avoid potentially costly and time-consuming changes
at the last minute.
“There’s no downside to thinking about
Step 1: Create a Proactive Communication Plan
these issues and having a communication
Although the new mandate for compliance is on brokers, fallout
from confusion about the legislation will land with advisory firms,
who own the client relationship. RIAs that can guide clients through
the complexities of the legislation will reinforce their firm’s value
and help to create a seamless transition for their clients.
plan in place—and the time to do it is
not when the phones are ringing.”
—Deanna Flores, Principal, KPMG LLP
“Even the basics are important to explain to clients—to minimize
call volume, confusion and frustration,” says Deanna Flores of
KPMG LLP, an audit, tax and advisory firm. She is a principal in the
firm’s Washington National Tax Financial Institutions and Products
group. “Advisors who help their clients anticipate the changes
under the new legislation and understand how it affects them will
have an opportunity to positively influence the relationship with
their clients,” Flores says.
6
THREE STEPS TO TAKE NOW
TowerGroup echoes this concern. The group’s
publication, “Cost Basis Technology for
Broker-Dealers: Build, Buy, or Both?”, written
by Sean Cunniff, research director, warns RIAs
to expect an uptick in call volume and visits
from clients, especially once clients learn that
cost information will be reported to the IRS.
“The firms with the client relationships need
to be prepared to handle these inquiries,”
the report notes.1
Brokers will be communicating directly with
investors in 2010 about the upcoming
changes. In particular, if you work with
multiple brokers, or if some of your clients
work with more than one advisor, those
clients may receive different information from
different sources.
Develop a plan to get ahead of those
communications and talk to your clients first.
Proactively reaching out to your clients can
help balance these discussions and reduce
any anxiety or confusion they may have about
the changes. Consider how you will educate
staff on the details of the legislation and its
implications for investors. Training tools, such
as webcasts on the topic, can help everyone
at the firm provide a consistent,
knowledgeable experience for clients.
Step 2: Anticipate Clients’ Needs
Clients will receive their first Form 1099-B
with cost basis data on covered equities in
early 2012—but some of your clients may
want to access cost basis information for all
securities, regardless of whether they are
covered by the legislation or not. Still others
may want cost basis information more
frequently than just at tax time. Firms that
can effectively meet these needs stand to
create a better experience for their clients.
Plan how—and if—your firm will address this
client need:
•Does your broker offer gain/loss reports?
Many brokers report gains and losses
and cost basis data on monthly account
statements as a value-added service. This
feature can help provide clients with the
information they need to report cost basis
information to the IRS for uncovered or
pre-effective date securities.
•Can you or your broker offer online account
access? Many brokers’ websites are set
up to provide cost basis data to your
clients. Consider enrolling interested
clients in this service.
•Does it make sense to generate gain/loss
reports for uncovered securities in-house?
If your firm already provides this service,
what steps should you take to reconcile
the data on your firm’s reports with the
information your brokers report?
1. Sean Cunniff, Research Director, TowerGroup, “Cost Basis Technology for Broker-Dealers: Build, Buy, or Both?” January 12, 2009 (www.towergroup.com).
7
PREPARING FOR THE NEW COST BASIS REGULATIONS
THE IMPORTANCE OF TALKING TO CLIENTS NOW
The complexity of the legislation will undoubtedly create concern among clients—even
more so when the mainstream media begin to report on it. Be prepared to educate
clients on what the legislation means and how it affects them. While some may
call their tax accountants with questions, advisory firms should be prepared for an
increase in call volume—either from clients directly or from their CPAs. Particular pain
points may include:
Lack of understanding about cost basis. Brokers will use their default method for
determining adjusted cost basis and gain/loss unless you or your client notifies the
broker directly to change it. Communicate the importance of working with you to
decide the best method, so that you can help your clients minimize their tax burden
throughout the year.
Confusion about covered holdings. Because the new rules roll out in three phases,
applying only to new securities acquired on or after those staggered dates, some
clients may be unsure of which transactions are covered and which are not. And
because brokers will be reporting to the IRS for covered securities, you can help make
tax preparation easier for your clients by providing them with cost basis information for
uncovered securities.
Concern about account transfers. Securities transferred from other brokers after the
legislation’s effective date will need to come with a transfer statement that includes
cost basis information. Clients may call you with questions about whether the cost
basis information was properly moved. If it wasn’t, the security will be considered
uncovered, and only the client will be responsible for determining and reporting cost
basis on that holding.
Questions about Form 1099-B. When clients receive Form 1099-B in early 2012, they
will see cost basis information for any equities they bought and sold in 2011—but
they will not be able to make any changes to the cost basis method used for each
trade, which could lead to confusion or frustration. They also may not understand why
the cost basis information for uncovered equities is not reported on their 1099-Bs.
8
THREE STEPS TO TAKE NOW
Step 3: Evaluate the Legislation’s
Impact on Your Back Office
Consider the areas where your firm’s back
office will be affected. For example:
The degree of impact to a firm’s back office
will depend on many factors, including:
•Trading. If you wish to use a method other
•The portfolio management software you use
•The number of brokers or custodians you
work with
•Whether or not you report cost basis to
clients or offer tax-sensitive investing
strategies
What’s more, the scope of changes to your
back office may depend on technology
upgrades that brokers are currently
developing. But even if your firm is still
awaiting guidance and direction from your
brokers, now is the time to evaluate how
your internal workflows and processes may
be affected.
Begin by evaluating your portfolio
management system, and consider how you
will ensure it is in synch with your broker’s
data. Some portfolio management systems
may require an extra step, or additional
software, to ensure that gain/loss data and
cost basis calculation methods used in your
trading strategies match what is on record
with your broker. Determine how your firm will
handle this reconciliation process.
than the FIFO default for determining gain/
loss, you will need to specify to your broker
before settlement—after that, the cost
information will be considered final.
•Data downloads and reconciliation.
Because a position in an account may
be made up of several lots, each with a
different cost basis, reconciliation will be
more complex than it is today. You may
also need to add a step to your firm’s
back-office workflow to ensure that there
are no discrepancies between your cost
basis information and your broker’s. If a
client reports cost basis information on
their tax return that differs from what was
reported on Form 1099-B, it could prompt
attention from the IRS.
•Transfers. “Covered” shares that are
transferred after the effective date will be
sent to you by the broker with cost basis
information.
“Worst case scenario, we’re prepared to hire
an additional person by end of year.”
—Jim Sinclair, David Vaughan Investments
9
PREPARING FOR THE NEW COST BASIS REGULATIONS
CASE STUDY
David Vaughan Investments
Location: Peoria, Illinois
Type of firm: Money manager
AUM: $1.2 billion
Focus: Equities
With a primary focus on their equity-income strategy, David
Vaughan Investments keeps its clients’ portfolios invested
primarily in equities that are diversified across several
industries. “The first phase of the legislation will affect us in a
major way,” says Jim Sinclair, CPA, treasurer and chief
compliance officer.
Sinclair says he still isn’t sure how big the impact will be,
particularly if some data will require manual entry or
reconciliation. “Worst case scenario, we’re prepared to hire an
additional person by end of year,” he explains. DVI is waiting for
direction from its multiple custodians to ensure accuracy and
consistency of cost basis data.
“Our hope is that the reconciliation process gets as
mechanized as possible. If the mechanization is not there,
somebody will have to physically do it,” says Sinclair.
“We have always focused on post-tax rates of return for
our taxable clients,” he adds. “Executing a tax-efficient
strategy requires flexibility and certainly the ability to use
lot identification. We have to track cost basis to make this
effective strategy work.”
The alternative—simply not providing cost basis information to
clients—is not a viable choice for DVI. “We’re going to provide
cost basis for our clients no matter what the cost,” Sinclair
says. “Some firms have said they’ll be getting out of the cost
basis business. For our clients, that’s not an option—it’s part
of DVI’s strategy and what they expect from us.”
10
•Gifting of shares. Shares must be
identified and applicable accounting
rules applied to the gain/loss.
•Corporate actions. The cost basis
information that your brokers report
on the Forms 1099-B must be
adjusted for corporate actions—which
may vary per broker.
•Wash sales. Although brokers will
report cost basis information for
all wash sales involving identical
securities within an account, investors
must report wash sales occurring
across other accounts. Some brokers
will accept customer-provided
information for those other wash
sales. Understand your broker’s policy
so you can help your clients track
sales for which they are responsible.
“The result of our conversations with our
custodians will determine the direction
we’ll go. We need to get closure on what
technology solutions might be available.”
—Mark Riley, The Milestone Group
THREE STEPS TO TAKE NOW
CASE STUDY
Again, it may be too early to fully assess how
your firm will need to react. “If we go too far
down the planning road, we may find that our
solution isn’t going to fit with what our
The Buckingham Family of Financial Services
Location: St. Louis, Missouri
Type: Wealth manager/TAMP
AUM: $12 billion
Focus: Mutual funds and fixed income
custodians roll out, or we may need to redo
some things,” explains Lori Dierke of
Accredited Investors Inc., a financial planning
firm in Edina, Minnesota. “But we’re keeping
up with what’s new and talking to our
custodians so that we can move as fast as
possible when the time comes.”
A large registered investment advisory firm with an in-house
affiliate that provides turnkey asset management services to 120
other RIAs, Buckingham has developed proprietary technology
solutions for its back-office processing. “We see the legislation as
more of a back-office issue than a client-facing issue,” says Ed
Goldberg, principal and investment advisor. “It will mainly affect
daily downloads, trading and reconciliation.”
Stay up to date on your brokers’ plans for
complying with the legislation, including
technology upgrades that may have
implications for your back office. Even if you
need more information from your brokers
before you move forward, now is the time to
evaluate how your firm may be affected and
determine what unknowns still remain.
The three most critical areas, he says, will be the ability to get
cost basis information in daily downloads, upload selected lot
information in trade files and synchronize systems with their
custodians. Once Buckingham’s three custodians develop these
capabilities, the firm plans to start integration work on its end to
synch with their systems.
“We have been suggesting that our clients ignore cost basis
information supplied by our custodians because we use the
selected-lot cost accounting methodology,” explains Goldberg.
“Now, that information matters, and we will have additional work
to reconcile our cost information to make sure it matches.”
For instance, Buckingham will need to redevelop the trade files
its proprietary trading application creates to provide selectedlot information to custodians. And each upload file will have
to be formatted to meet the requirements of each of the three
custodians. Goldberg is also concerned about having enough
time to determine and upload lot information when a trade
occurs so they can receive it back in the next day’s download.
Even though Buckingham trades mainly in mutual funds, the
firm expects that it will need to be ready for the equity phase
on January 1, 2011, since many clients hold legacy equities
in their accounts.
11
PREPARING FOR THE NEW COST BASIS REGULATIONS
OPPORTUNITIES
The changes resulting from this legislation offer several potential benefits for firms and
their clients. For advisors, it creates the opportunity to build loyalty, consolidate client assets
and, for those who do not do so already, offer tax-efficient investment strategies. Clients, for
their part, will have access to accurate information that allows them to see
the tax consequences of their trades immediately.
Build Loyalty
By helping to guide clients through the complexity of the
legislation, advisors stand to enhance their value to their clients.
Moreover, for advisors who have clients with multiple advisors,
this is an opportunity to demonstrate the value of working
uniquely with them. For instance, firms that offer gain/loss
reports for their clients’ uncovered securities may gain a
competitive advantage over those that do not.
According to TowerGroup, advisors who help their clients through
the transition stand to win: “The U.S. tax code has grown in
complexity over time. Advisors who can help their clients navigate
this warren of obstacles will be the winners in the long term.”2
12
2. TowerGroup, “Cost Basis Technology for Broker-Dealers: Build, Buy, or Both?”
OPPORTUNITIES
Consolidate Clients’ Assets
Your clients will receive Forms 1099-B from
all of your firm’s brokers with whom they
have accounts. And if clients work with
multiple advisors, this experience could be
complicated. Use this opportunity to talk to
your clients about consolidating assets with
your firm. This can help make tax preparation
simpler and more accurate.
Offer Tax-Efficient
Investment Strategies
If your firm does not already provide taxefficient investment strategies, now may be a
good time to implement this offering. With
real-time cost basis information, your firm
may be better positioned to make
recommendations on what lot to trade based
on a client’s tax situation. TowerGroup
underscores the importance of offering these
services to clients: “…advisors who
embrace tax-efficient investing strategies will
gain attention in the low-return environment
expected for the next several years and will
gain market share.”3
3. TowerGroup, “Cost Basis Technology for Broker-Dealers: Build, Buy, or Both?”
HOW THE LEGISLATION
CAN BENEFIT YOUR CLIENTS
It makes tax preparation easier.
The legislation eases the burden of cost basis
reporting for investors.
It can help give clients more information about their
total tax picture.
Many brokers are planning to make available real-time
information about the tax consequences of a trade.
This will help clients to take a more active role in their
tax planning. Clients who work with nondiscretionary
advisors and place trades themselves will be able to
compare the tax consequences of different cost
basis methods.
It minimizes year-end surprises.
Your clients will be able to see the effects of a
trade on their tax impact—and make changes—as
positions are sold.
13
PREPARING FOR THE NEW COST BASIS REGULATIONS
CONCLUSION
Adjusting to the new cost basis reporting requirements will require
planning, and those advisory firms that remain committed to easing
the transition for clients stand to build relationships and reinforce
value. The sooner firms begin to think critically about how the
legislation will affect both clients and their back offices, the better
prepared they will be when the first phase begins on January 1, 2011.
KEY TAKEAWAYS
• Preparing now for the new cost basis regulations is critical.
Although brokers shoulder most of the burden to comply, your
firm should begin to get ready for workflow changes and client
questions. Staying on top of news from brokers is vital for
preparing the back office.
• Taking steps now to prepare your firm and your clients can lead to
stronger client relationships and can help avoid difficult workflow
issues later. Proactively communicating with clients will be key to
uncovering potential opportunities.
14
APPENDIX
APPENDIX: FIRMS INTERVIEWED
We thank the firms listed below for their participation and for the insight they shared during
interviews for this project.
Firm name
Location
Accredited Investors Inc.
Edina, MN
The Buckingham Family of Financial Services
St. Louis, MO
David Vaughan Investments
Peoria, IL
KPMG LLP, Washington National Tax Financial Institutions and Products
San Diego, CA
The Milestone Group
Denver, CO
15
PREPARING FOR THE NEW COST BASIS REGULATIONS
APPENDIX: SAMPLE CLIENT POSITIONS
This chart shows a sample of a client’s positions as of June 30, 2011.
EQUITY
HOLDINGS
IBM
General
Electric
QUANTITY
MARKET
PRICE
MARKET
VALUE
Units
Purchased
Cost per
Share
Cost Basis
Apple Inc.
Apple
Cost Basis
UNREALIZED
GAIN (OR LOSS)
HOLDING
PERIOD
600
$26.00
$15,600.00
600
$30.00
$18,000.00
4,050.00
$102.53
$415,246.50
1,850.00
$100.05
$185,092.50
3/25/2011
$4,588.00
Short-Term
2,200.00
$99.47
$218,834.00
$403,926.50
5/10/2002
$6,732.00
Long-Term
2,000.00
$125.3846
$250,769.20
2,000.00
$99.00
$198,000.00
7,000.00
$81.252
$568,764.00
3,000.00
$67.2234
$201,670.20
5/15/2011
$42,085.80
Short-Term
3,500.00
$70.2564
$245,897.40
5/12/2005
$38,484.60
Long-Term
500
$65.00
$32,500.00
$480,067.60
2/26/2001
$8,126.00
Long-Term
GE Cost Basis
Chevron
ASSETS
ACQUIRED
Total Equities
$1,250,379.70
Total
Cost Basis
$1,099,994.10
($2,400.00)
2/26/2001
($2,400.00)
Long-Term
$11,320.00
$52,769.20
5/20/2005
$52,769.20
Long-Term
$88,696.40
$150,385.60
= “Covered securities” under the legislation and therefore reportable to the IRS by Schwab once sold.
= “Uncovered securities” and therefore reportable to the IRS by the account holder (taxpayer) once sold.
For an explanation of covered and uncovered securities, see page 3.
16
APPENDIX
APPENDIX: SAMPLE FORM 1099-B
Let’s say the account holder sells all of these positions on December 15, 2011. In late January 2012, they
would receive a Form 1099-B that might look like this:*
Account Number: XXXX-XXXX
Taxpayer ID: ***-**-1234
Proceeds from Broker Transactions – 2011
Form 1099-B
Description
IBM
Quantity
600 Sale Date
12/15/11
Cost Basis
$18,000.00
Uncovered
Y
ST/LT Gain
LT
Gross Proceeds
$15,600.00
GE
1850
12/15/11
$185,092.50
N
ST
$189,680.05
GE
2200
12/15/11
$218,834.00
Y
LT
$225,566.00
Chevron
2000
12/15/11
$198,000.00
Y
LT
$250,769.20
Apple Inc.
3000
12/15/11
$201,670.20
N
ST
$243,756.00
Apple Inc.
3500
12/15/11
$245,897.40
Y
LT
$284,382.00
Apple Inc.
500
12/15/11
$32,500.00
Y
LT
$40,626.00
NOTE: THIS IS FOR ILLUSTRATIVE PURPOSES ONLY—IT IS NOT A REPRESENTATION OF WHAT THE NEW FORM 1099-B
WILL LOOK LIKE, NOR DOES IT CONTAIN ALL OF THE IRS REQUIRED INFORMATION.
17
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