Our Commitment
Real Fiduciary™
We hold ourselves to the highest fiduciary standard because we believe it's the single most important element when choosing any professional. This is our code of conduct.
The Foundation
Three Fiduciary Duties
Every decision we make is governed by these three duties — the legal and ethical bedrock of fiduciary responsibility.
Duty of Loyalty
An advisor must act solely in the interest of the client and must not place their own interests ahead of the client’s. This means no conflicts, no self-dealing, and no compensation structures that could compromise objectivity.
Practices 1–4
Duty of Due Care
An advisor must act with the competence, diligence, and good judgment of a professional. This means maintaining expertise, documenting the basis for advice, and following a disciplined investment process.
Practices 5–8
Duty of Utmost Good Faith
An advisor must act honestly and transparently in all dealings with clients. This means declining gifts that could impair objectivity and charging fees that are reasonable and fully disclosed.
Practices 9–10
The Standard
The 10 Real Fiduciary™ Practices
Established by the Institute for the Fiduciary Standard. We adhere to every one.
Demonstrate Loyalty
Act as a fiduciary at all times. Affirm this commitment to the client in writing.
Demonstrate LoyaltyAffirm that the fiduciary standard under common law and the Investment Advisers Act of 1940 (and when applicable, ERISA) governs all professional advisory client relationships at all times at both the advisor and the firm level.
Decline any sales-related compensation.
Demonstrate LoyaltyAccept compensation that is paid by the client in the form of a percentage of assets under management, retainers, fixed fees, or hourly fees. Decline any compensation associated with transactions and product sales such as commissions, shelf space payments, and 12b-1 fees.
Avoid conflicts of interest.
Demonstrate LoyaltyUnderstand that a conflict of interest occurs when the interests of the advisor or the advisor’s firm interfere with the advisor’s fiduciary duties to clients. A conflict is material when it could reasonably be deemed to affect how a client who understands the conflict decides to act. Material conflicts are inherently harmful. Eliminating or avoiding these conflicts when possible has been the cornerstone of fiduciary law for centuries.
Mitigate unavoidable conflicts.
Demonstrate LoyaltyMitigating material conflicts means, at minimum, receiving appropriate client consent before executing the recommendation. The advisor will: Explain the conflict in sufficient detail, both orally and in writing, so the client fully understands the conflict. Ensure that the client understands the implications of the conflict. Receive informed, intelligent and independent consent from the client in writing before any advice is implemented. Document and be prepared to demonstrate that the conflicted advice remains reasonable and fair and consistent with the client’s best interest.
Act With Due Care
Maintain professional knowledge and competence.
Act With Due CareDemonstrate baseline competence by holding a recognized designation that requires significant study and knowledge, experience, and ongoing continuing education requirements, such as the CFP®, CPA/PFS, or CFA designations. Decline to provide advice, regardless of its scope, unless the advisor possesses the appropriate expertise.
Explain agreements and disclosures clearly and truthfully, both orally and in writing.
Act With Due CarePut all important client agreements and disclosures in writing. Do not make oral or written statements that are misleading. Client understanding of the advisor’s actions is important in relationships of trust and confidence.
Establish and document a reasonable basis for advice.
Act With Due CareDocument relevant facts and circumstances supporting the advisor’s advice in a manner that is appropriate for the scope and nature of the client engagement and for the client’s goals and overall circumstances. Upon client request, provide a brief summary written in plain language of each recommendation and its respective reasonable basis.
Follow and document a prudent due diligence process for rendering investment advice.
Act With Due CareResearch and analyze investment vehicles in a responsible manner. Use an investment policy statement that is based on a clear understanding of the client’s circumstances and preferences and that clearly specifies assumptions regarding objectives, risk, and performance. Report performance based on data supplied by an independent third party and calculated using industry-standard methods.
Act In Utmost Good Faith
Decline gifts or entertainment or other benefits unless minimal in value, occasional in frequency, and consistent with the advisory firm’s gift and vendor relation policies.
Act In Utmost Good FaithDecline any gifts or third-party compensation or other benefits received by the advisor or the advisor’s firm that could impair advisor objectivity. Upon request, provide the firm’s policy on gifts and entertainment.
Charge reasonable fees and incur reasonable investment costs. Disclose and fully explain.
Act In Utmost Good FaithProvide in writing at the outset of the advisory relationship, and upon request throughout the client engagement, a good faith description and estimate of anticipated fees, investment costs, and tax implications. Have procedures to check that client expenses are reasonable.
Governance
Real Fiduciary™ Practices Board
The individuals who established and oversee the Real Fiduciary™ standard.
Work with a firm held to the highest fiduciary standard.
No commissions. No product sales. No conflicts. Just advice built entirely around your best interest.
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