As a fiduciary, we are legally required to act in the client's best interest at all times. This means:

• Documenting the basis for all investment recommendations
• Disclosing any conflicts of interest in writing
• Recommending only suitable products based on client profile
• Maintaining complete and accurate account records
• Following Regulation Best Interest (Reg BI) requirements

All client records must be maintained per SEC Rule 17a-4 and LPL retention schedules:

• Account opening documents: retain for life of account + 6 years
• Trade confirmations and statements: 6 years
• Client correspondence: 3 years minimum
• Use LPL-approved archiving systems only
• No client data on personal devices without MDM enrollment

All client communications must be conducted through LPL-approved channels:

• Use LPL email system for all client correspondence
• Personal email addresses (e.g., Gmail) may not be used for client business
• Text messaging with clients requires LPL-approved compliant texting platform
• Social media posts that reference specific securities require pre-approval
• Response time standard: within one business day for all client inquiries

LinkedIn and other social media must comply with FINRA Rule 2210:

• All advisor LinkedIn profiles must list LPL Financial affiliation
• No performance claims without proper context and disclaimers
• No screenshots of client portfolios or account data
• Educational content is encouraged — submit to compliance for review first
• Client interactions on social media must be documented

Protecting client personal and financial information is a legal obligation under Gramm-Leach-Bliley Act (GLBA) and other regulations:

• Never share client PII via unencrypted email
• Use LPL's secure document portal for sensitive document exchange
• Strong passwords required — minimum 12 characters, MFA enabled
• Lock screens when away from desk (auto-lock after 5 minutes)
• Report any suspected data breach to compliance within 24 hours
• Annual cybersecurity training mandatory for all staff

Client information is strictly confidential and may not be shared without explicit written consent:

• Do not discuss client accounts in public spaces
• Obtain written authorization before sharing with third parties
• Annual privacy notice must be delivered to all clients
• Honor all opt-out requests for information sharing

• Enter complete meeting notes in CRM within same business day
• Create tasks for all action items committed to
• Send client a meeting summary email within 24 hours
• Submit any required forms or account changes
• Schedule next review meeting if not done in meeting
• Update client profile with any new information gathered

Our investment philosophy is grounded in evidence-based, long-term wealth building:

• Asset Allocation: Tailored to client risk tolerance, time horizon, and goals
• Diversification: Across asset classes, geographies, and sectors
• Low-cost investing: Emphasis on ETFs and institutional share classes
• Tax efficiency: Asset location strategy (tax-advantaged vs. taxable)
• Rebalancing: Threshold-based rebalancing (typically 5% drift triggers review)

Model Portfolios: Conservative (30/70), Moderate (60/40), Growth (80/20), Aggressive Growth (95/5). Custom allocations available for complex situations.

We provide estate planning education and coordinate with estate attorneys. Key topics:

• Will & Trust: Every client should have a current will. Revocable living trusts avoid probate.
• Beneficiary Designations: Review annually. Supersede will provisions on retirement accounts and life insurance.
• Power of Attorney: Financial and healthcare POA critical for all clients
• 2025 Federal Estate Tax Exemption: $13.61 million per individual (scheduled to sunset end of 2025)
• Annual Gift Exclusion: $18,000 per recipient in 2025

• Tax-loss harvesting: Offset capital gains by selling losing positions
• Qualified Opportunity Zones: Defer and potentially reduce capital gains
• Charitable Giving: DAFs, QCDs from IRAs (age 70½+), appreciated securities
• Social Security Timing: Delay to 70 for maximum benefit when feasible
• Medicare IRMAA: Plan income to avoid surcharges — 2-year lookback
• Roth Conversions: Fill lower tax brackets strategically before RMDs begin

• Life Insurance: Term for income replacement, permanent for estate planning
• Disability Insurance: Protects income — often overlooked. Own-occupation preferred.
• Long-Term Care: Hybrid life/LTC products growing in popularity
• Umbrella Policy: Recommend to all HNW clients — $1M+ coverage
• Coordinate with client's P&C and life insurance agents

Client complaints must be handled per LPL's complaint procedure:

1. Acknowledge receipt of complaint within 1 business day
2. Notify compliance immediately — do not attempt to resolve alone
3. Document all communications related to the complaint
4. LPL compliance will guide resolution process
5. Never make promises of compensation without compliance approval