The market for investment products and services is very competitive. Consumers now look to their advisers to not only provide return on their investment but to do so in a way that is consistent with their personal ethos. To meet this demand, many investment advisers have turned to incorporating environmental, social, and governance (“ESG”) factors
registered investment adviser
Confused By The Signs? SEC Publishes Annual Guide to Examination Priorities
Our recent posts have walked you through the SEC’s new marketing rule and discussed valuation and fee assessment. Now, with the ADV season, hopefully, in your rear-view mirror, we turn your attention to planning for the remainder of the year. Determining the most efficient use of a compliance department’s time and resources is essential. Fortunately,…
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,…
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…
Compliance with Solicitation: How to Build a Strong Referral Base
The saying goes, referrals are the lifeblood of any business. Indeed, all business owners, robo-advisory firms included, strive to provide a level of value and service to their customers such that those customers in turn become advocates and solicitors of the business. Unfortunately, word of mouth referrals alone are not usually enough. Your firm may…
Providing Advice in a Digital World: Applying the Suitability Standard to Robo-Advisers

All investment advisers must provide advice suitable for a particular client based on the client’s financial situation and investment objectives. Traditional investment advisers usually do this after getting to know their clients through conversations and other forms of direct communication. Robo-advisers, by contrast, must accomplish this through other means. Given this universal duty, it’s important…
Robo-adviser client agreements – are your bases covered?

Thanks for taking the time to check out our first of many blog posts designed to help robo-advisers operate more efficiently, reduce business risk, and comply with applicable law.
To start, when we say “robo-advisers” or “you,” we mean registered investment advisers that use technology to provide discretionary asset management services to their clients through…