We are an investment advisor and provide advisory accounts and services rather than brokerage accounts and services. “Advisory accounts and services” means we, for compensation, are engaged in the business of providing advice to others or issuing reports or analyses regarding securities. “Brokerage accounts and services” are transactional—for facilitating the buying and selling of securities and investment products. If you do not want or need advice about securities, a brokerage account may be more appropriate.
“Advice about securities” means:
i. advice about market trends is advice about securities;
ii. advice about the selection and retention of other advisors is advice about securities;
iii. advice about the advantages of investing in securities versus other types of investments (e.g., coins or real estate) is advice about securities;
iv. providing a selective list of securities is advice about securities even if no advice is provided for any one security; and
v. asset allocation advice is advice about securities
As advisors, we are subject to a fiduciary standard that includes:
Duty Of Care. Fiduciaries have a duty of care to their clients (in addition to a duty of loyalty) that they actually take steps to ensure that the advice they’re providing for their clients actually is the right and proper advice, which would include:
• A duty to provide best interests advice. When providing personalized investment advice, the investment advisor would have a duty to make a reasonable inquiry into the client’s financial situation, level of financial sophistication, investment experience and investment objectives, beyond making a recommendation (with the breadth of diligence based on the breadth and scope of the advice engagement).