compliance

Ensure investment advertising and marketing materials comply with SEC Marketing Rule and FINRA Rule 2210. Use when the user asks about performance advertising, showing backtested or hypothetical returns, net vs gross performance presentation, client testimonials or endorsements in marketing, social media posts by advisers or reps, third-party ratings in pitchbooks, or advertising recordkeeping. Also trigger when users mention 'can we show this track record', 'pitchbook compliance review', 'marketing rule violations', 'cherry-picking performance periods', 'predecessor performance portability', 'extracted performance', or ask whether a website, one-pager, or presentation needs compliance approval.

Determine when a product, platform, or communication crosses the regulatory line from education into investment advice requiring registration. Use when the user asks about the definition of investment advice under the Advisers Act, whether a fintech feature or AI chatbot constitutes advice, the publisher's exclusion for newsletters or model portfolios, broker-dealer solely incidental exclusion, what triggers a 'recommendation' under Reg BI, or DOL education vs advice safe harbors. Also trigger when users ask 'do I need to register as an investment adviser', 'does this app give investment advice', 'is this tool just education or advice', 'robo-adviser registration', or 'disclaimer language for financial content'.

Guide BSA/AML compliance program design and operation for broker-dealers, banks, and investment advisers. Use when the user asks about suspicious activity reports, currency transaction reports, OFAC screening, structuring detection, or FinCEN requirements. Also trigger when users mention 'large cash deposit', 'sanctions check', 'money laundering red flags', 'customer risk rating', 'unusual transaction patterns', 'wire to a foreign country', 'SDN list', 'tipping off a client about a SAR', 'AML audit', 'correspondent account due diligence', or ask whether a transaction needs to be reported.

Guide the design and maintenance of recordkeeping programs under SEC Rules 17a-3, 17a-4, and 204-2. Use when the user asks about document retention schedules, how long to keep trade records or customer complaints, WORM storage requirements, email or text message archiving, social media capture, BYOD compliance policies, or electronic storage audit trails. Also trigger when users mention 'we got an exam request for records', 'migrating to a new archiving vendor', 'blotter retention', 'order ticket requirements', 'off-channel communications', 'WhatsApp archiving', or ask how long specific records must be kept.

Guide the creation, content, and delivery of required client disclosure documents for investment advisers and broker-dealers. Use when the user asks about Form ADV Part 2A or 2B content, Form CRS requirements, prospectus delivery obligations, privacy notice delivery, trade confirmation timing, account statement distribution, or electronic vs paper delivery compliance. Also trigger when users mention 'onboarding document checklist', 'what disclosures do we owe new clients', 'annual brochure update', 'brochure supplement for a new adviser', 'CRS conversation starters', or ask when and how disclosure documents must be delivered.

Identify, disclose, and mitigate conflicts of interest in advisory and brokerage relationships under Reg BI and fiduciary duty. Use when the user asks about compensation-based conflicts, proprietary product incentives, revenue sharing disclosure, principal trading consent, soft dollar arrangements, pay-to-play restrictions, gifts and entertainment limits, personal trading policies, or code of ethics requirements. Also trigger when users mention 'is this a conflict', 'recommending our own funds', 'higher payout on annuities', 'outside business activity conflicts', 'allocation fairness across accounts', 'political contribution to a pension board member', or ask how to disclose or eliminate a conflict.

Prepare for and respond to SEC and FINRA regulatory examinations across the full exam lifecycle. Use when the user asks about exam notification letters, document request lists, deficiency letter responses, mock examination programs, annual compliance reviews under Rule 206(4)-7, or SEC/FINRA examination priorities. Also trigger when users mention 'we just got an exam letter', 'preparing for our first SEC exam', 'how to respond to a deficiency finding', 'staff interview preparation', 'what does OCIE look for', 'examination readiness checklist', 'sweep exam on off-channel comms', or ask what to expect during a regulatory audit.

Guide fee disclosure compliance across advisory, brokerage, fund, and retirement plan contexts. Use when the user asks about Form ADV Item 5 fee schedules, prospectus fee table format, Reg BI cost disclosure obligations, 12b-1 fee transparency, revenue sharing arrangements, wrap fee program costs, or ERISA 408(b)(2) service provider fee disclosure. Also trigger when users mention 'hidden fees', 'total cost to the client', 'are we disclosing all layers of fees', 'expense ratio comparison', 'fee billing in advance vs arrears', 'share class selection', 'indirect compensation', or ask whether fee disclosures are complete and compliant.

Apply fiduciary duty standards across the investment advisory landscape, including IA Act Section 206, ERISA, DOL rules, and CFA Institute standards. Use when the user asks whether a fiduciary standard applies, how fiduciary duty differs from Reg BI or suitability, what the duty of care and duty of loyalty require, ERISA Section 404 prudent expert obligations, PTE 2020-02 rollover exemptions, or state-level fiduciary developments. Also trigger when users mention 'are we a fiduciary here', 'best interest vs suitability', 'dual registrant hat switching', 'retirement plan adviser obligations', 'DOL fiduciary rule', or ask what standard of care applies to a recommendation.

Ensure investment firms satisfy CFA Institute GIPS requirements for composite construction, performance calculation, presentation, and verification. Use when the user asks about building composites, time-weighted return calculation, GIPS-compliant presentations, error correction policies, pooled fund reporting, wrap fee or SMA program performance, or GIPS advertising guidelines. Also trigger when users mention 'claiming GIPS compliance', 'composite membership rules', 'terminated portfolio returns', 'gross vs net of fees under GIPS', 'GIPS verification findings', 'can we show this track record to prospects', or ask whether a firm's performance reporting meets GIPS standards.

Assess investment suitability obligations under FINRA Rules 2111 and 2090 across all three suitability prongs. Use when the user asks about reasonable-basis, customer-specific, or quantitative suitability, product-specific concerns for complex products, leveraged ETFs, variable annuities, or alternatives, household-level suitability, hold recommendations, or the institutional suitability exemption. Also trigger when users mention 'is this investment suitable', 'turnover ratio is too high', 'cost-to-equity ratio', 'churning metrics', 'suitability questionnaire design', 'complex product due diligence', 'customer refused to provide their risk tolerance', or ask whether a recommendation fits a customer's profile.

Guide the implementation of customer identification, due diligence, and ongoing monitoring under FINRA Rule 2090, CIP, and the FinCEN CDD Rule. Use when the user asks about customer onboarding identity verification, beneficial ownership collection for entity accounts, enhanced due diligence for PEPs or high-risk customers, customer risk rating systems, KYC refresh triggers, or documentary vs non-documentary verification. Also trigger when users mention 'account opening requirements', 'who is the beneficial owner', 'new client identity check', 'how often to update KYC', 'essential facts for the account', 'foreign customer onboarding', or ask what information must be gathered before opening an account.

Design and operate privacy and data security programs for SEC-registered firms under Reg S-P, Reg S-ID, and SEC cybersecurity expectations. Use when the user asks about privacy notices, the Safeguards Rule, identity theft prevention programs, breach notification obligations, vendor security due diligence, incident response planning, data classification, or state privacy law compliance. Also trigger when users mention 'customer data was exposed', 'do we need to notify clients of a breach', 'cybersecurity exam prep', 'cloud vendor risk assessment', 'encrypting client data', 'BYOD security policy', 'Red Flags Rule', 'NY DFS 500 requirements', or ask how to handle a cybersecurity incident.

Analyze broker-dealer recommendations under SEC Regulation Best Interest's four obligations: Disclosure, Care, Conflict of Interest, and Compliance. Use when the user asks whether a recommendation satisfies Reg BI, what triggers the 'recommendation' standard, how to evaluate reasonably available alternatives, rollover recommendation compliance, dual-registrant capacity disclosure, share class or account type recommendations, or Reg BI examination preparation. Also trigger when users mention 'best interest standard for brokers', 'is this a Reg BI recommendation', 'care obligation documentation', 'sales contest elimination requirement', 'Form CRS delivery', or ask how Reg BI differs from suitability or fiduciary duty.

Guide regulatory filing obligations and deadlines for investment advisers, broker-dealers, and large traders. Use when the user asks about Form PF filing thresholds, 13F institutional holdings reports, 13H large trader filings, Form ADV amendment timing, FOCUS report preparation, blue sheet requests, CAT reporting infrastructure, or FINRA short interest and TRACE reporting. Also trigger when users mention 'filing deadline calendar', 'do we need to file Form PF', 'crossed the $100M 13F threshold', 'annual updating amendment', 'CAT clock synchronization', 'how to respond to a blue sheet request', 'FOCUS report errors', or ask which regulatory filings a firm must make and when.

Identify and prevent sales practice violations under FINRA and SEC rules governing broker-dealer conduct. Use when the user asks about churning or excessive trading metrics, mutual fund breakpoint discounts, selling away or private securities transactions, outside business activities, unauthorized trading, supervisory procedure design, senior investor protections, trusted contact persons, variable annuity suitability, or options account approval. Also trigger when users mention 'turnover ratio is high', 'rep did trades without authorization', 'breakpoint abuse', 'trusted contact for elderly client', 'selling away from the firm', 'supervision failure', '1035 exchange review', 'marking the close', or ask whether a broker's conduct violates FINRA rules.