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 investment adviser registration. Use when the user asks about the definition of investment advice under Advisers Act Section 202(a)(11), whether a fintech feature or AI chatbot constitutes advice, the publisher's exclusion for newsletters or model portfolios, the broker-dealer solely incidental exclusion, adviser registration thresholds and exemptions, 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'. (For what triggers a 'recommendation' under Reg BI, use reg-bi.)

Guide BSA/AML compliance program design, ongoing transaction monitoring, and FinCEN reporting for broker-dealers, banks, and investment advisers. Use when the user asks about suspicious activity reports, currency transaction reports, OFAC screening, structuring detection, ongoing risk-rating reviews and escalation, or FinCEN requirements. Also trigger when users mention 'large cash deposit', 'sanctions check', 'money laundering red flags', '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. (For onboarding identity verification, CIP/CDD, beneficial ownership, and initial customer risk rating, use know-your-customer.)

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 which client disclosure documents must exist, what each must contain, and when and how they must be delivered to clients of investment advisers and broker-dealers. Use when the user asks about Form ADV Part 2A or 2B content, Form CRS content and delivery, prospectus delivery obligations, privacy notice delivery, trade confirmation timing, account statement distribution, electronic vs paper delivery compliance, or the content and client-delivery side of the annual brochure update. Also trigger when users mention 'onboarding document checklist', 'what disclosures do we owe new clients', 'brochure supplement for a new adviser', or 'CRS conversation starters'. (For filing mechanics and regulatory deadlines — IARD amendments, Form PF, 13F — use regulatory-reporting; for whether fee disclosure content is adequate, use fee-disclosure.)

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.

Evaluate whether the substance of fee and cost disclosures is complete, accurate, and not misleading across advisory, brokerage, fund, and retirement plan contexts. Use when the user asks whether Form ADV Item 5 fee content is adequate, prospectus fee table format, Reg BI cost disclosure content, 12b-1 fee transparency, revenue sharing arrangements, wrap fee program cost-effectiveness, or ERISA 408(b)(2)/404a-5 fee disclosure content. 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', or 'indirect compensation'. (For which disclosure documents must exist and when they are delivered, use client-disclosures.)

Apply the investment adviser fiduciary duty (IA Act Section 206), ERISA fiduciary standards, the DOL fiduciary rule and PTE 2020-02, and state fiduciary rules. Use when the user asks whether a fiduciary standard applies, what the duty of care and duty of loyalty require of an adviser, ERISA Section 404 prudent expert obligations, PTE 2020-02 rollover exemption conditions, DOL fiduciary rulemaking status, or state-level fiduciary developments. Also trigger when users mention 'are we a fiduciary here', 'retirement plan adviser obligations', 'DOL fiduciary rule', or 'dual registrant hat switching' from the adviser side. (For the broker-dealer best-interest standard and the canonical Reg BI vs fiduciary comparison, use reg-bi.)

Ensure firms claiming GIPS compliance under the CFA Institute Global Investment Performance Standards satisfy requirements for composite construction, performance calculation, presentation, and verification. Use when the user asks about building composites, time-weighted return calculation under GIPS, GIPS Reports and pooled fund reports, error correction policies, wrap fee or SMA program performance under GIPS, GIPS verification, 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', or 'GIPS verification findings'. (For SEC Marketing Rule and FINRA 2210 regulatory compliance of marketing materials, use advertising-compliance.)

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 and concentration analysis, hold recommendations, or the institutional suitability exemption. Also trigger when users mention 'is this investment suitable', 'suitability questionnaire design', 'complex product due diligence', 'concentrated position in a client account', 'customer refused to provide their risk tolerance', or ask whether a recommendation fits a customer's profile. (For churning, turnover-ratio, and excessive-trading enforcement triggers, use sales-practices.)

Guide customer onboarding identification, due diligence, and profile maintenance under FINRA Rule 2090, the CIP rules, and the FinCEN CDD Rule. Use when the user asks about onboarding identity verification, beneficial ownership collection for entity accounts, enhanced due diligence for PEPs or high-risk customers at account opening, assigning the initial customer risk rating, 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. (For ongoing transaction monitoring, SAR filing, and surveillance-driven risk re-rating, use anti-money-laundering.)

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 private placement and exempt offering compliance under Regulation D, the Investment Company Act fund exclusions, and FINRA private placement rules. Owns the accredited investor definition (Rule 501(a)), the '506(b) vs 506(c)' distinction, 'general solicitation' analysis, 'Form D' filing mechanics, the 'qualified purchaser' standard for 3(c)(7) funds, bad-actor disqualification, integration, and Rule 144 resale restrictions. Use when the user asks 'can my client invest in this private fund', whether an investor is an 'accredited investor' or qualified purchaser, how to verify accredited status in a 'Reg D offering', 506(c) verification steps, FINRA 5122/5123 filing obligations, or the Reg BI/fiduciary overlay when recommending private placements. Also trigger on 'exempt offering', 'private fund exemption', '3(c)(1) vs 3(c)(7)', or 'restricted securities holding period'.

Analyze the broker-dealer standard of conduct under SEC Regulation Best Interest's four obligations: Disclosure, Care, Conflict of Interest, and Compliance. Owns what triggers a 'recommendation' under Reg BI and the canonical comparison of Reg BI vs FINRA suitability vs IA fiduciary duty. Use when the user asks whether a broker-dealer recommendation satisfies Reg BI, 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', or ask how Reg BI differs from suitability or fiduciary duty. (For the IA fiduciary duty itself and DOL rules, use fiduciary-standards.)

Guide regulatory filing mechanics and deadlines for investment advisers, broker-dealers, and large traders — which forms to file, where, and by when. Use when the user asks about Form PF filing thresholds, 13F institutional holdings reports, 13H large trader filings, Form ADV amendment filing timing (including the annual updating amendment filed via IARD), 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', 'CAT clock synchronization', 'how to respond to a blue sheet request', or 'FOCUS report errors'. (For what the ADV brochure must contain and when it must be delivered to clients, use client-disclosures.)

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.