Insights

Compliance and risk

Examinations, best execution, the basis for a recommendation, rollover documentation, and what ‘risk score’ actually means.

Compliance

Best execution, in practice →

A firm can obtain excellent execution and still fail the obligation.

Compliance

Composites, and what GIPS means →

Using the methodology and claiming compliance are different things.

Risk

Risk tolerance is not one question →

Tolerance, capacity and requirement collapsed into one score — and where that misleads.

Compliance

The alternative you didn't choose →

Every proposal documents what was recommended. Almost none document why.

Risk

The chatbot problem →

Someone at your firm is pasting client holdings into a chatbot right now.

Risk

The rep-as-PM problem →

A large share of advisors became discretionary managers without deciding to. The workload is the visible part.

Compliance

What an examination is actually testing →

Mostly whether you can demonstrate what you did, not whether you did wrong.

Compliance

Texting, WhatsApp, and the record →

The violation is rarely what was said — it is that the firm could not produce it.

Compliance

Custody you didn't know you had →

Custody attaches to authority, not possession.

Compliance

Can advisors use testimonials? →

The modernized advertising rule replaced a flat prohibition with a conditional permission.

Compliance

Outside business activities →

Board seats, rental property, the family business on weekends.

Compliance

Who owns the record? →

The question at the end of every examination is not what you recommended — it is whether you can show it.

Questions? Ask them directly — that is what the twenty minutes is for.

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