So you’ve built your robo-adviser, registered it, hired and licensed personnel, implemented a compliance program, conducted a successful marketing campaign, and (finally) gotten to do what you’ve really wanted to do the whole time – advise clients and manage portfolios.  Startup woes seem a thing of the past, and your operation is running smoothly.

Then,

Robo-advisory firms often build client portfolios with exchange-traded funds (ETFs) and mutual funds.  This makes practical sense – these instruments allow advisers to efficiently meet a wide range of client investment objectives.  Nevertheless, as mentioned in our last post, the SEC’s Division of Exams (EXAMS) has made it a priority this year to focus