The Fiduciary Fallacy
The standard news release that advisors make when going independent is beginning to sound rote. “I have left Wall Street to start my own firm where I will be a fiduciary. This will allow me to show you unlimited investment options without any institutional constraints. I’m a fiduciary now and have the obligation to always act in your best interest.” This positioning is a fallacy because there is much more to the fiduciary standard. The other items aren’t as compelling but they are essential for new fiduciaries.
Tools
Most independent wealth advisory firms service mass affluent
clients a fact confirmed by the recent FA survey. We are in the early innings of a Gold Rush in asset flows to
independent advisors, but do they all need the same picks and shovels to find
the gold? The clients and the
fiduciary police don’t think the answer is yes.
The products and services can be broken down to three major
categories.
Investment
solutions
Consolidated
Reporting
Alternative
investment needs*
* Ultra affluent clients
Investment solutions
are the place most firms start. The
market share leaders are DFA, TAMPs , wrap programs and robo solutions. Unfortunately these solutions won’t
feel that different than your old firm and won’t deliver on your press release
to find the best.
Consolidated
Reporting is a service that will be a definite upgrade from your old firm and
there a several flavors available from Black Diamond, eMoney, Envestnet and
Addepar. Each tastes and costs different.
The final area addresses the unique needs of ultra affluent
clients. This client segment is
demanding and wants to invest in hedge funds, private equity and is VERY fee sensative . Large firms like Hall Management, Tiedemann,
Inconiq, and BBR have experts in their firm to address these needs. A common asset of many ultra affluent
clients is restricted or concentrated stock. Wall Street trys to solve this problem by offering complex
high margin solutions. Fiduciaries can provide this advice too with the help of, Parametric, Spiderrock or the new
firm StratiFi at a fraction of the cost and with Wall Street
sophistication.
Special Counsel
Independent advisory firms might need their own special
counsel to help them address how to compliantly choose their client solutions. Most decisions are typically made with
the assistance of wholesalers, custodians or large platform firms. Each has their own set of conflicts or
lack of expertise. Service
providers might not like it but advisors might need a special counsel to
confirm the veracity of their product and service decisions.
The good news is we have several special counsels to choose
from. The first and most important
is the SEC, which during a review will ask the firm for due diligence files on
each of the products and services they offer clients. The largest firms create their due diligence files by
establishing a separate investment committee. Smaller advisors default to their personal opinion when choosing
the best solution. We did NOT collude with The Russians!
Cost
Establishing a firm that will meet the fiduciary duty of
care isn’t cheap. The first check
I recommend you write is for training for you and your entire team. The best firms I have found are Aspire!,
Altius Financial and Cannon Financial.
Building a fiduciary-based business that meets the fiduciary
standard of care provision will be more expensive than the custodians and other
consultants tell you. I remember the
advice I received early in my career from Bill Good. He recommended that if you want to build a great business you
need to invest a significant portion of your yearly compensation back into in your business. That advice went over my head as a rookie advisor, but after
40 years Bill is still in business and I’m writing blogs….
Other coverage of The Standard of Care
ReplyDeletehttp://financialadvisoriq.com/c/1711103/201513/must_address_duty_care_fiduciary_rule?referrer_module=emailReminder&module_order=3&login=1&code=WVdWd2MzUmxhVzVBYzJGdVkzUjFZWEo1ZDNNdVkyOXRMQ0EwTXprME9EUXpMQ0F4T0RnMk9ETTROVFk0#
I should have added custodian services to my Tools section. RIABiz did that for me in a recent article that is a good read. https://riabiz.com/a/2018/8/29/twitter-war-pits-josh-downtown-brown-against-michael-kitces-over-hush-hush-issue-do-ria-custodians-face-merrill-lynch-style-conflicts-over-advisor-custody-fees
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