If you can believe it, May 1, 2020 is almost upon us. And if you don’t remember from our February post, that is the day when advisory firms serving retail investors may start filing client relationship summaries on Form CRS. As a reminder, Form CRS gives clients a quick summary of the key things
SEC Extends Form ADV Filing and Delivery Deadlines due to Coronavirus
As Josh discussed earlier this week, the annual update to Form ADV is generally due at the end of March for most robo-advisers. However, we are interrupting our current discussion thread to make sure you were aware that on March 13, 2020, the SEC extended Form ADV filing and delivery deadlines for investment advisers whose
The Secret Ingredient – Disclosure of Your Algorithm
With the deadline for the annual update to Form ADV closing in at the end of March, let’s examine one aspect of Form ADV disclosure which impacts a majority, if not all, robo-advisory firms – algorithm related disclosure.
Your firm likely utilizes a proprietary algorithm to automatically determine client asset allocation among a limited set
New Form CRS – What You Need to Know Now
OK, so remember last June when we discussed registering your firm? If you do, you may recall that the principal adviser registration document, Form ADV, is divided into two parts: Part 1 (a check-the-box form that is mostly for use by the regulator) and Part 2 (a narrative brochure that is the principal client
Hypothetically Speaking – Advertising your Back-Tested Performance
In our last post, Craig laid out the process of advertising a performance track record. That’s great, if you have a track record. What about a newly operational robo-adviser with no performance history? Your firm likely has spent considerable resources building and developing an investment strategy and corresponding algorithm. But without a client base,
Bringing Up the Past – Advertising Your Track Record
Let’s say that five years ago, you developed an investment strategy and built an algorithm to execute it. Since then, your robo-adviser has managed several client accounts using that algorithm. Much to your delight, the strategy weathered the ups and downs of the market and to date, has produced very favorable returns. Now, you want
Don’t Oversell It – False or Misleading Advertising
You’re ready to advertise. You know the basics, you can handle the complexities of including past specific recommendations, and even understand how to appropriately include client testimonials. Let the advertising campaign commence! Well, not so fast. Even if you’ve successfully managed all of the potential pitfalls we’ve discussed so far, you must