STRATA Trust Company

Dear Ms. [redacted]:           We are in receipt of your complaint notice regarding the above-referenced customer. We appreciate the opportunity to respond to Mr. [redacted]’s concerns regarding his account.   STRATA Trust Company (“STRATA”) mailed an...

invoice to Mr. [redacted] which was returned as undeliverable. As a result of not having a current address on file, STRATA contacted Mr. [redacted] through his email of record on January 15, 2018 notifying him of the returned mail and requested an address update. On January 21, 2018, Mr. [redacted] signed and returned an address change form to STRATA, and the updated address was changed in our system on January 22, 2018. Clearly, there was not a delay in processing the address update as specified in Mr. [redacted]’s correspondence with the Revdex.com. We will provide Mr. [redacted] with a written confirmation of the change.   Our year-end statement file was created and sent to our vendor for mailing on January 19, 2018. If Mr. [redacted] happened to receive his year-end statement at the old address, it was because the address change form with his updated address was received by STRATA after our year-end statements were processed.   We trust that this response provides the information the Revdex.com needs for its resolution process.  However, you may contact me directly at ###-###-#### if you need any additional information including copies of any of the documents referenced here.  Again, we appreciate the opportunity to respond to this matter.   Sincerely,     [redacted]VP Compliance/Risk Management

February 25, 2015                     [redacted]     Revdex.com [redacted]         Austin, TX  [redacted]   Re:  ...

[redacted] IRA - Revdex.com Complaint ID [redacted]   Dear Ms. [redacted]:           We are in receipt of your complaint notice regarding the above-referenced customer. We appreciate the opportunity to respond to Mr. [redacted]’s concerns regarding his instructions to purchase precious metals from [redacted] (“[redacted]”) using his IRA funds.   Self Directed IRA Services, Inc.  (“SDIRA”) is a wholly-owned subsidiary of [redacted] Bank, and there is no ownership affiliation between SDIRA and [redacted].  SDIRA serves only in the capacity of a directed IRA custodian, meaning that all accounts are self directed by the account owner and SDIRA acts only upon the customer’s instructions.  [redacted] is a precious metals dealer which handles precious metals transactions (buys, sales, and exchanges) for its customers.  In doing so, [redacted] may refer its customers to open an IRA account when a customer wishes to invest in precious metals using IRA funds.    Mr. [redacted] provided SDIRA with a completed and signed Investment Direction for Precious Metals form on or about August 28, 2014 instructing SDIRA to wire funds from his IRA to [redacted] to purchase proof gold coins and uncirculated burnished silver coins. SDIRA processed the wire transfer of $34,193.16 to [redacted] on August 29, 2014 in accordance with Mr. [redacted]’s instructions. SDIRA’s precious metals depository received the precious metals shipment from [redacted] on or about October 10, 2014 to fully settle the transaction.   SDIRA’s September 30, 2014 quarterly statement reported the [redacted] transaction of $34,193.16 as pending (unsettled) since the precious metals had not yet been delivered to SDIRA’s depository at quarter end. This is the amount Mr. [redacted] referenced in his complaint. However, once the precious metals were delivered to the depository in October, SDIRA posted the specific precious metals holdings to Mr. [redacted]’s IRA at cost, and the valuation reflected was based on spot price, which is substantially lower.     As disclosed on SDIRA’s IRA Financial Disclosure as well as each quarterly statement Mr. [redacted] received, all precious metal values reported on our account statements and online records reflect the spot value which is the current spot price multiplied by the ounces of fine metal contained in the coin or bar.  In the precious metals industry, spot values are considered to be one of the more conservative values, as spot prices do not include any mark-ups, mark-downs, premiums or commissions charged by the dealer.  This is important considering Mr. [redacted] purchased proof and uncirculated coins which generally carry higher premiums and/or commissions depending on the broker or dealer.  Spot values should be used as an indication of value only and should not be construed as a firm bid price to buy by any broker or dealer.  The actual precious metals type and quantity of a transaction may affect the price received for any given bullion item.  Before making a decision to buy or sell any specific bullion product, an IRA owner is urged to obtain and compare pricing from various sources, including his precious metal dealer.   If Mr. [redacted] is unhappy with the purchase he directed, he will need to contact [redacted] since that is the firm from which he chose to purchase the precious metals. SDIRA does not offer or sell investments, so any potential dispute regarding the specific purchase is between Mr. [redacted] and [redacted]. SDIRA acts only in the capacity as a directed IRA custodian, and in doing so, processed Mr. [redacted]’s instructions to purchase the precious metals within his IRA. SDIRA will gladly provide Mr. [redacted] with additional copies of either his investment instructions or SDIRA’s valuation policy contained in his account application and disclosed on each quarterly statement.   We hope this information helps with Mr. [redacted]’s understanding of SDIRA’s role as a directed IRA custodian as well as the valuation policy with regards to precious metals.  It does not appear that he tried to contact us prior to filing this complaint with the Revdex.com, however, he may contact our Client Services Manager, [redacted], at 866-[redacted] with any further questions regarding his account.   We trust that this response provides the information the Revdex.com needs for its resolution process.  However, you may contact me directly at 866-[redacted] if you need any additional information regarding this matter.  Again, we appreciate the opportunity to respond to this matter.   Sincerely,     [redacted] VP Compliance/Risk Management

Revdex.com:
I have reviewed the response made by the business in reference to complaint ID [redacted], and find that this resolution is satisfactory to me.
Regards,
[redacted]

Complaint: [redacted]
I am rejecting this response because: I am showing a market value on 10/01/2014 of $34,215.53 from SDIRA, and then an ending market value  on 12/31/2014, of $15,905.79. Explanation? A line item above suggesting "change in investment value"  -$18,309.74. This is toyally unacceptable and undeniably a misuse of trust in the banking industry. I expect banks to protect my money, not lose it.
Regards,
[redacted]

Complaint: [redacted]
I am rejecting this response because:  Based on the lawsuits I have reviewed regarding self directed IRA's, it is evident that the custodian has responsibility for the collection of assets.  This is not an "investment" loss!  The assets were never collected and delivered to my account.  There are no assets in my account to either gain or loose value.  I have no means to collect assets, the custodian does, and failed to do so. 
Regards,
[redacted]

We are in receipt of your complaint notice regarding the above-referenced customer. We appreciate the opportunity to respond to Mr. [redacted]’s concerns regarding his account. STRATA Trust Company (“STRATA”) is a wholly-owned subsidiary of Horizon Bank and...

serves only in the capacity of a directed IRA custodian. This means that all accounts are self-directed by the account owner, and STRATA acts only upon the customer’s instructions.  STRATA only charges a nominal annual fee and ancillary processing fees for its custodial services and does not use any hard sales tactics when an individual is interested in opening an account with us. It appears Mr. [redacted] was referred to STRATA by American Bullion, a precious metals dealer which handles precious metals transactions (buys, sales, and exchanges) for its customers.  There is no ownership affiliation between STRATA and American Bullion, so we are not aware of the sales tactics or discussions Mr. [redacted] may have had with American Bullion in 2012 prior to his decision to open an account with STRATA. When an individual completes a STRATA IRA application, a comprehensive fee schedule is included along with the application, custodial agreement, disclosure statement, and financial disclosure. Our fee schedule clearly outlines the new account establishment fee, annual fee, termination fee, and ancillary fees such as wire fees or processing fees. When Mr. [redacted] signed the IRA application in 2012, he acknowledged receipt of these documents including the fee schedule. Contrary to Mr. [redacted]’s complaint, the fees are clearly outlined and not “buried into some legal disclosure”. In addition to the fee schedule provided in 2012, STRATA has updated and revised its fee schedule twice since then. The first revision was provided to all customers with their December 31, 2014 quarterly statements. The second revision was communicated to customers in their June 30, 2016 quarterly statements. In both cases, the termination fee, annual fee, and all processing fees were clearly outlined in the fee schedule. The termination fee outlined in the most current fee schedule is $250. The processing fee for liquidating precious metals is $40 and was already charged when he liquidated his holdings. As a gesture of goodwill, STRATA will refund $100 and only charge a termination fee of $150 which was in effect in 2012 when Mr. [redacted] first established his account.  We trust that this response provides the information the Revdex.com needs for its resolution process.  However, you may contact me directly at ###-###-#### if you need any additional information including copies of any of the documents referenced here.  Again, we appreciate the opportunity to respond to this matter. Sincerely,  [redacted]VP Compliance/Risk Management