The problem, says Hough, is that each little piece of the business often requires compliance procedures and oversight, he says. "It's a full-time responsibility for part-time pay," he says.
Supervising full-time employees is often an imperfect science, says Hough. A thorough compliance program may still not detect certain practices in which some full-time advisors engage beyond the firm's walls, such as selling away, a practice in which brokers conduct private securities transactions without their firm's supervision. That risk only increases among part-time employees, who are even more difficult to monitor.
Firms with part-time advisors should require them to sign an independent contractor agreement outlining their responsibilities, says Pedregon. Part-timers should also have access to the firm's email systems, so the compliance department can monitor their communications. Many part-timers historically gravitated to free personal email providers, he says.
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