In the design and management of investment portfolios, both brokers (under Reg BI) and investment advisors (as fiduciaries) possess a duty of due care. This includes undertaking sufficient due diligence as to both investment strategies, as well as in the investment product selection process. As discussed below, in April 2023 the Staff of the U.S. Securities and Exchange Commission issued guidance in which adherence to the duty of due care was discussed in some detail.
First, I discuss the general legal principles that inform one’s adherence to the duty of due care.
THE DUTY OF DUE CARE, GENERALLY
While many commentators and jurists express the exercise of “due care” as an aspect of “ordinary care,” others have delved deeper. “Ordinary care” is determined by reference to what a hypothetical reasonable person would do. “Due care” is the standard applied to professional malpractice and is determined by reference to what a hypothetical professional would do. See Robert E. Drechsel, The Legal Risks of Social Responsibility (1987). Black’s Law Dictionary states that a fiduciary is “[s]omeone who is required to act for the benefit of another person on all matters within the scope of their relationship; one who owes to another the duties of good faith, loyalty, due care and disclosure.” Fiduciary, Black’s Law Dictionary (11th edition 2019). See also, e.g., SEC vs. Duncan (U.S.D.C., Mass., 9/15/21): “Defendant’s failure to investigate the legitimacy of the Turkish investment was a breach of his fiduciary duty to exercise due care.” U.S. courts have in large part adopted the view of fiduciary obligations as resting upon “the triads of their fiduciary duty—good faith, loyalty or due care.” See In re Alh Holdings LLC, 675 F.Supp.2d 462, 477 (D. Del., 2009). See, e.g., Restatement (Third) of the Law of Agency (2006), § 808 Duties of Care, Competence, And Diligence. “Subject to any agreement with the principal, an agent has a duty to the principal to act with the care, competence, and diligence normally exercised by agents in similar circumstances. Special skills or knowledge possessed by an agent are circumstances to be taken into account in determining whether the agent acted with due care and diligence. If an agent claims to possess special skills or knowledge, the agent has a duty to the principal to act with the care, competence, and diligence normally exercised by agents with such skills or knowledge.” [Emphasis added.]
“An adviser’s fiduciary duty applies to all investment advice the investment adviser provides to clients, including advice about investment strategy, engaging a sub-adviser, and account type.”[1] “The duty of care includes, among other things: (i) the duty to provide advice that is in the best interest of the client, (ii) the duty to seek best execution of a client’s transactions where the adviser has the responsibility to select broker-dealers to execute client trades, and (iii) the duty to provide advice and monitoring over the course of the relationship.”[2]
In order to provide investment advice, and as part of the exercise of due care the investment adviser exercises, the investment adviser must possess “a reasonable understanding of the client’s objectives. The basis for such a reasonable understanding generally would include, for retail clients, an understanding of the investment profile, or for institutional clients, an understanding of the investment mandate.”[3] Adherence to the duty of due care also requires periodic updating of the client’s investment profile or investment mandate, as appropriate.[4] When updating of an investment profile or mandate is undertaken, the investment adviser should consider any material changes to the client’s situation, as well as external factors such as changes in tax laws.[5]
[1] SEC Interpretation of Fiduciary, at p.18.
[2] Id., at p.12.
[3] Id., at p.13.
[4] “For example, when the adviser has an ongoing relationship with a client and is compensated with a periodic asset-based fee, the adviser’s duty to provide advice and monitoring will be relatively extensive as is consistent with the nature of the relationship.” Id. at p.20. “However, an adviser and client may scope the frequency of the adviser’s monitoring (e.g., agreement to monitor quarterly or monthly and as appropriate in between based on market events), provided that there is full and fair disclosure and informed consent.” Id. at fn.50 on p.20.
[5] “[I]it will generally be necessary for an adviser to a retail client to update the client’s investment profile in order to maintain a reasonable understanding of the client’s objectives and adjust the advice to reflect any changed circumstances. The frequency with which the adviser must update the client’s investment profile in order to consider changes to any advice the adviser provides would itself turn on the facts and circumstances, including whether the adviser is aware of events that have occurred that could render inaccurate or incomplete the investment profile on which the adviser currently bases its advice. For instance, in the case of a financial plan where the investment adviser also provides advice on an ongoing basis, a change in the relevant tax law or knowledge that the client has retired or experienced a change in marital status could trigger an obligation to make a new inquiry. By contrast, in providing investment advice to institutional clients, the nature and extent of the reasonable inquiry into the client’s objectives generally is shaped by the specific investment mandates from those clients. For example, an investment adviser engaged to advise on an institutional client’s investment grade bond portfolio would need to gain a reasonable understanding of the client’s objectives within that bond portfolio, but not the client’s objectives within its entire investment portfolio. Similarly, an investment adviser whose client is a registered investment company or a private fund would need to have a reasonable understanding of the fund’s investment guidelines and objectives. For advisers acting on specific investment mandates for institutional clients, particularly funds, we believe that the obligation to update the client’s objectives would not be applicable except as may be set forth in the advisory agreement.” Id., at pp.14-15.
“A reasonable belief that investment advice is in the best interest of a client also requires that an adviser conduct a reasonable investigation into the investment sufficient not to base its advice on materially inaccurate or incomplete information.”
“The investment adviser’s fiduciary duty is broad and principles-based; it applies to the entire adviser-client relationship.” (SEC Interpretation of Fiduciary, at p.6 and p.9.)
THE DUTY OF CARE IS THAT OF A PROFESSIONAL, NOT A LAY PERSON
While the duty of care of a broker, under Reg BI, remains subject to further definition, it is clear that the duty of care of an investment adviser is that of a professional.
The standard of prudence is relational, and it follows that the standard of care for investment advisers is the standard of a prudent investment adviser. By way of explanation, the standard of care for professionals is that of prudent professionals; for amateurs, it is the standard of prudent amateurs. For example, Restatement of Trusts 2d § 174 (1959) provides: “The trustee is under a duty to the beneficiary in administering the trust to exercise such care and skill as a man of ordinary prudence would exercise in dealing with his own property; and if the trustee has or procures his appointment as trustee by representing that he has greater skill than that of a man of ordinary prudence, he is under a duty to exercise such skill.” Case law strongly supports the concept of the higher standard of care for the trustee representing itself to be expert or professional. See Annot., “Standard of Care Required of Trustee Representing Itself to Have Expert Knowledge or Skill”, 91 A.L.R. 3d 904 (1979) & 1992 Supp. at 48-49.
It should further be noted that adherence to the duty of due care is not satisfied once by the investment adviser, as the standard of care itself is always evolving. Investment advisers are expected to adhere to an “expert” standard of care, but even this test applied is not static. The knowledge and expertise required of the investment adviser community, and the process undertaken, and judgment required, evolves over time. As investment advisers’ knowledge regarding investment management and its delivery improves, and better techniques and practices become widely accepted, investment advisers must continually adapt their practices to meet the “prudent expert” test applied to investment advisers. Moreover, as new risks to investors become known, or risks become more likely to be realized (for example, because of changes in market structures or investment product design), measures to guard against those risks must be addressed appropriately by the investment adviser.
EVIDENCE OF THE STANDARD OF CARE MAY BE FOUND IN ASSOCIATION CODES
As a general principle, an association’s “Code of Ethics” or its “Rules of Professional Conduct” do not establish an independent cause of action. Additionally, ethics rules, even when mandatory on professionals pursuant to law, do not establish standards of care unless such as intended “by language that is clear, unambiguous, and peremptory.” [1]
However, ethics codes can be utilized as evidence of the standard of care. Stated differently, while ethics codes do not in and of themselves define standards for civil liability, the standards stated in a code of ethics or rules of professional conduct are not irrelevant in determining the standard of care in certain actions for malpractice.
[1] Peck v. Meda-Care Ambulance Corp., 457 N.W.2d 538, 542 (Wis.Ct.App.1990). In an earlier Montana Supreme Court decision the consumer argued that a publication of the American Institute of Architects (AIA), “The Architects’ Handbook of Professional Practice” (AIA Handbook) should have been admitted into evidence as controlling authority to establish the architects’ standard of care. The trial court allowed the AIA Handbook book into evidence. On appeal, the Montana Supreme Court acknowledged that, “The [AIA] handbook describes the standard of practice for architects in the United States.” The consumer desired a ruling a ruling that any deviation from the standards set forth in that AIA Handbook should be deemed outright negligence, without any further proof (a legal theory known as “negligence per se”), as occurs with deviations from statutory requirements. The Montana Supreme Court would not go that far, however, and instead ruled that: “While violation of a statute may be classed as negligence per se, violation of other regulations is not generally classed as negligence per se. More precisely on point, absent specific statutory incorporation, the provisions of a national code are only evidence of negligence, not conclusive proof thereof.” Taylor, Thon, Thompson & Peterson v. Cannaday, 230 Mont. 151, 749 P.2d 63, 65 (Mont. 1988). See also Elledge v. Richland/Lexington School Dist., 534 S.E.2d 289 (S.C. Ct. App., 2000), stating: “Evidence of industry standards, customs, and practices is ‘often highly probative when defining a standard of care.’ 57A Am. Jur. 2d Negligence 185 (1999) … (‘[E]vidence of custom within a particular industry, group, or organization is admissible as bearing on the standard of care in determining negligence.’ (quoting Muncie Aviation Corp. v. Party Doll Fleet, Inc., 519 F.2d 1178, 1180 (5th Cir. 1975))); Brown v. Clark Equip. Co., 618 P.2d 267, 276 (Haw. 1980) (finding safety data, codes or standards promulgated by voluntary industry organizations ‘admissible as evidence on the issue of negligence’ and ‘as an alternative to or utilized to buttress expert testimony’).”
For example, when an investment adviser belongs to an association, that association’s code of ethics may provide guidance in ascertaining the professional’s obligations to their clients under various circumstances, and conduct which violates the code of ethics may also constitute a breach of the standard of care due a client. Expert witnesses in cases involving financial and investment advisers often turn to the standards adopted by various organizations, such as the Certified Financial Planner Board of Standards, Inc., the CFA Institute, and the AICPA’s Personal Financial Planning division.
Additionally, in an examination by securities regulators, the use of association codes and standards of conduct may be relevant in assessing compliance by the investment adviser with her or his fiduciary standard of due care.
“REASONABLE BASIS” DUE CARE. IS THIS A LOW STANDARD?
Under the Investment Advisers Act, and as “part of their care obligations, broker-dealers, investment advisers, and their financial professionals must develop an understanding of the investment or investment strategy to form a reasonable basis for making recommendations or providing advice to retail investors. What is reasonable depends on the facts and circumstances, and the specific terms and features that a firm or financial professional would need to understand about the investment or investment strategy under consideration will necessarily vary.”[1]
“A reasonable belief that investment advice is in the best interest of a client also requires that an adviser conduct a reasonable investigation into the investment sufficient not to base its advice on materially inaccurate or incomplete information. We have taken enforcement action where an investment adviser did not independently or reasonably investigate securities before recommending them to clients.”[2]
A “reasonable basis” is also sometimes referred to as possessing of an “adequate basis.”[3]
In contrast to the obligations of investment advisers, for brokers (i.e., registered representatives of broker-dealer firms, who engage in the sale of securities, such as stocks, bonds, and mutual funds), the duty of care is currently set forth by Regulation Best Interest (“Reg BI”)[4] and enhances the low suitability standard of conduct. The duty of care for brokers applies only the time of a recommendation[5] of a security or an investment strategy,[6] and generally tracks and incorporates[7] the structure of FINRA’s suitability rule[8] by providing that:
- The broker “understands the potential risks, rewards, and costs[9] associated with the recommendation, and have a reasonable basis to believe that the recommendation could be in the best interest of at least some retail customers”;[10]
- the broker has “a reasonable basis to believe that the recommendation is in the best interest of a particular retail customer based on that retail customer’s investment profile and the potential risks, rewards, and costs associated with the recommendation and does not place the financial or other interest of the broker, dealer, or such natural person ahead of the interest of the retail customer”;[11] and
- the broker has a reasonable basis to believe that a series of recommended transactions, even if in the retail customer’s best interest when viewed in isolation, is not excessive and is in the retail customer’s best interest when taken together in light of the retail customer’s investment profile.[12]
While the SEC inferred in Reg BI that broker-dealer firms should train their brokers (i.e., registered representatives) on how to determine whether a reasonable basis exists for any recommendations made,[13] there is no definition provided in Reg BI as to what constitutes a “reasonable basis” for investment recommendations.
And, while Reg BI imposes upon brokers a duty to always[14] consider costs as one of many factors, including costs other than those disclosed on trade confirmations and account statements,[15] there is no apparent duty for broker-dealers to minimize costs borne by the investor. In fact, the SEC has stated that “[c]ost is only one of many important factors to be considered regarding the recommendation and that the standard does not necessarily require the ‘lowest cost option’,” and that brokers are entitled to recommend products that are more expensive and provide greater compensation to the brokerage firm.[16]
In contrast, investment advisers – those who provide investment advice for a fee paid directly by a client possess a fiduciary duty of due care. However, it is unclear whether, as applied by the SEC, the “reasonable basis” required of an investment adviser in adherence to the investment adviser’s duty of care is more strictly applied than the “reasonable basis” required of a broker. Is a broker, similar to an investment adviser, now regarded as a “professional”? Is the knowledge and expertise required of broker in providing investment recommendations lower than the knowledge and expertise required of an investment adviser?
Regardless of whether the “reasonable basis” standard varies when applied to either brokers or investment advisers, it is submitted by this author that what constitutes as “reasonable basis” is subject to a wide variance of interpretation. Given the large number of investment strategies and securities, the “reasonable basis” standard constitutes, in fact, a somewhat low standard of due care. Accordingly, as set forth in the next section, it is recommended that the client insist that the investment adviser adhere to the prudent investor rule when undertaking investment strategy decisions, undertaking due diligence leading to fund selection, and generally during the investment design and management process.
[1] Staff Bulletin: Standards of Conduct for Broker-Dealers and Investment Advisers Care Obligations (April 23, 2023).
[2] SEC Interpretation of Fiduciary, supra note 2.
[3] “The broker or advisor implicitly represents to the client that he or she has an adequate basis for the opinions or advice being provided.” Johnson v. John Hancock Funds, No. M2005-00356-COA-R3-CV (Tenn. App. 6/30/2006) (Tenn. App., 2006), citing Hanly v. S.E.C., 415 F.2d 589, 596-97 (2d Cir. 1969); Univ. Hill Found. v. Goldman, 422 F. Supp. 879, 893 (S.D.N.Y. 1976).
[4] 17 C.F.R. §240.15l-1. Published at 84 Fed. Reg. 33,319-33,492) (July 12, 2019).
[5] As part of the general “best interest obligation,” the care obligation applies to a broker “when making a recommendation of any securities transaction or investment strategy involving securities (including account recommendations) to a retail customer ….” 17 C.F.R. §240.15/-1(a)(1); 84 Fed. Reg. 33491.
[6] Id.
[7] In the preamble to the final rule, the SEC stated that the “care obligation” imposed by Reg BI “Care Obligation was intended to “incorporate and enhance existing suitability requirements applicable to broker-dealers….” 17 CFR 33372.
[8] Rule 2111(a)
[9] The explicit duty to consider the costs of a recommendation was an addition to Reg BI’s care obligation in the Final Rule, not expressly stated in the SEC’s proposed rule. See 84 Fed. Reg. 33,444. “[W] when determining whether a recommendation is in a retail customer’s best interest with respect to cost or other relevant factors, broker-dealers and their associated persons should consider reasonably available alternatives.” Id. The obligation to consider reasonably available alternatives was not an obligation found under FINRA’s suitability rule. Id. In the preamble to the Final Rule, the SEC stated its belief that this explicit requirement in Reg BI to consider costs will benefit investors by reducing “the incidence of recommendations of higher cost investments from a set of reasonably available alternatives” [83 Fed. Reg. 33,445]. “If the explicit requirement to consider the cost of a recommendation encourages broker-dealers and their associated persons to more carefully consider cost, compared to the baseline, the final rule makes it less likely that a broker-dealer or its associated persons could have a reasonable basis to believe such investments are in the retail customer’s best interest because it would be difficult to have such a belief for investments that are identical beyond their costs.”
[10] 17 C.F.R. §240.15/-1(a)(2)(ii)((A); 84 Fed. Reg. 33,491.
[11] 17 C.F.R. §240.15/-1(a)(2)(ii)((B); 84 Fed. Reg. 33,491.
[12] 17 C.F.R. §240.15/-1(a)(2)(ii)((C); 84 Fed. Reg. 33,491.
[13] 84 Fed. Reg. 33,455.
[14] 84 Fed. Reg. 33,373.
[15] SEC Staff Bulletin on Duty of Care, supra n.2, stating: “when determining whether an investment or investment strategy is in the investor’s best interest, in the staff’s view, the firm and financial professional should consider, where relevant, the following non-exhaustive list of potential costs: commissions, markups or markdowns, and other transaction costs; sales loads or charges; advisory or management fees; other fees or expenses that may affect a retail investor’s return (such as Rule 12b-1 fees, other administrative and service fees, revenue sharing, and transfer agent fees); the trading and other costs associated with an investment strategy (such as the need to continually buy and sell options or futures contracts or pay margin interest, daily rebalance fees, and any structural features of the investment that could magnify investor losses); the costs of exiting an investment or investment strategy (such as deferred sales charges or liquidation costs); any relevant tax considerations; and the likely impacts of those costs over the retail investor’s expected time horizon. In other words, an analysis of costs, in the staff’s view, should include costs beyond the explicit costs disclosed on a trade confirmation or account statement.”
[16] 84 Fed. Reg. 33,326. In the preamble to the Final Rule, the SEC opined: “Regulation Best Interest will allow a broker-dealer to recommend products that entail higher costs or risks for the retail customer, or that result in greater compensation to the broker-dealer, or that are more expensive, than other products, provided that the broker-dealer complies with the specific component obligations detailed below, including the requirement to make these recommendations exercising reasonable diligence, care, and skill to have a reasonable basis to believe that the recommendation is in the retail customer’s best interest and does not place the broker-dealer’s interest ahead of the retail customer’s interest.” 84 Fed. Reg. 33,334.
THE SEC STAFF ADDRESS DUE DILIGENCE (AND ITS DOCUMENTATION)
On April 23, 2023, the U.S. Securities and Exchange Commission staff promulgated a bulletin, “Standards of Conduct for Broker-Dealers and Investment Advisers Care Obligations, in which it focused on the duty of care.
Excerpts from this bulletin follow (with citations omitted).
In the context of providing investment advice and recommendations to retail investors, the care obligations generally include three overarching and intersecting components. As discussed in more detail in the following questions and answers, these components are:
- Understanding the potential risks, rewards, and costs associated with a product, investment strategy, account type, or series of transactions (the “investment or investment strategy”);
- Having a reasonable understanding of the specific retail investor’s investment profile, which generally includes the retail investor’s financial situation (including current income) and needs; investments; assets and debts; marital status; tax status; age; investment time horizon; liquidity needs; risk tolerance; investment experience; investment objectives and financial goals; and any other information the retail investor may disclose in connection with the recommendation or advice; and
- Based on the understanding of the first two elements, as well as, in the staff’s view, a consideration of reasonably available alternatives, having a reasonable basis to conclude that the recommendation or advice provided is in the retail investor’s best interest.
Whether a recommendation or advice satisfies the care obligations is an objective evaluation, turning on the facts and circumstances of the particular recommendation or advice and the investment profile of the particular retail investor at the time the recommendation is made or when the advice is provided. When adopting and implementing reasonably designed policies and procedures regarding their care obligations, broker-dealers and investment advisers should tailor those policies and procedures, taking into consideration their particular business models and relationships with retail investors …
As part of their care obligations, broker-dealers, investment advisers, and their financial professionals must develop an understanding of the investment or investment strategy to form a reasonable basis for making recommendations or providing advice to retail investors. What is reasonable depends on the facts and circumstances, and the specific terms and features that a firm or financial professional would need to understand about the investment or investment strategy under consideration will necessarily vary.
The following is a non-exhaustive list that the staff believes are some of the important factors that may be relevant to consider as part of evaluating the potential risks, rewards, and costs of an investment or investment strategy:
- the objectives of the investment or investment strategy (such as whether it is designed to provide income, principal protection, growth, or exposure to a specific market sector, or is designed to be held for a long or short term);
- the initial and ongoing costs of the investment or investment strategy (such as direct and indirect costs, as well as potential costs, such as redemption fees);
- the investment or investment strategy’s key characteristics and risks (such as liquidity or volatility), or other features that may impact the investment (e.g., margin call terms or early repayment of debt underlying a securitized product);
- the investment or investment strategy’s likely performance in a variety of market and economic conditions;
- the expected returns, expected payout rates, and potential losses of the investment or investment strategy;
- any special or unusual features of the investment or investment strategy (such as tax advantages or guaranteed payments); and
- the role of the investment or investment strategy within the context of the retail investor’s actual or anticipated investment portfolio.
Where there is an ongoing monitoring obligation, the reasonable investigation will require continued analysis after purchase of the investment and over the course of the relationship …
While costs should not be the only consideration, and a firm or financial professional cannot satisfy its obligations simply by recommending the lowest cost option, the firm and financial professional must always consider cost as a factor when providing a recommendation or advice to a retail investor. In the staff’s view, the firm and financial professional should consider the total potential costs when evaluating whether the recommendation or advice is in a retail investor’s best interest, including direct and indirect costs that could be borne by the retail investor. For example, when determining whether an investment or investment strategy is in the investor’s best interest, in the staff’s view, the firm and financial professional should consider, where relevant, the following non-exhaustive list of potential costs: commissions, markups or markdowns, and other transaction costs; sales loads or charges; advisory or management fees; other fees or expenses that may affect a retail investor’s return (such as Rule 12b-1 fees, other administrative and service fees, revenue sharing, and transfer agent fees); the trading and other costs associated with an investment strategy (such as the need to continually buy and sell options or futures contracts or pay margin interest, daily rebalance fees, and any structural features of the investment that could magnify investor losses); the costs of exiting an investment or investment strategy (such as deferred sales charges or liquidation costs); any relevant tax considerations; and the likely impacts of those costs over the retail investor’s expected time horizon. In other words, an analysis of costs, in the staff’s view, should include costs beyond the explicit costs disclosed on a trade confirmation or account statement …
There are many investments and investment strategies where a primary feature may be a tax advantage for the investor (e.g., 529 plans, tax loss harvesting, opportunity zone funds, donor-advised funds, direct and custom indexing, variable annuities, government securities, 401(k) accounts, and IRAs). Where a retail investor or a financial professional identifies a goal with tax implications (e.g., including, but not limited to, saving for retirement or a child’s education) or seeks to obtain a particular tax advantage (e.g., tax loss harvesting or limiting capital gains) as an investment objective, the staff believes that a firm and its financial professionals should consider whether the tax-advantaged option covered by their recommendation or advice is in the best interest of the retail investor based on the retail investor’s investment profile.
An investor’s or account’s tax status may also be an important consideration when selecting or providing advice on a particular investment or investment strategy relative to other options – such as whether a fixed income investment pays taxable, tax-free, or deferred interest, whether an out of state 529 plan is in the best interest of a customer who lives in a state that offers tax benefits for investing in the home state’s plan, or whether a buy-and-hold or more frequent trading strategy is best for a particular account. Still, the staff believes the existence of a tax advantage alone would not provide a reasonable belief that a recommendation or particular advice would be in the retail investor’s best interest.
Ultimately, the staff believes a factor such as tax advantage should be considered in light of the other features of the investment or investment strategies (including, but not limited to, limitations on withdrawal), reasonably available alternatives, and the retail investor’s entire investment profile, including the retail investor’s investment time horizon. If a retail investor already has one or more tax advantaged investments, the staff believes that factor generally should be considered when recommending or providing advice regarding another tax advantaged investment …
[F]irms should have and implement a reasonable process for establishing and understanding the scope of such reasonably available alternatives that should be considered as part of satisfying their care obligations. When providing ongoing advice or services (e.g., ongoing monitoring), this may include both evaluation of alternatives prior to investment and consideration of alternative investments throughout the investment period …
Although there is no requirement of such documentation, in the staff’s view, it may be difficult for a firm to demonstrate compliance with its obligations to retail investors, or periodically assess the adequacy and effectiveness of its written policies and procedures, without documenting the basis for certain recommendations. This could include documentation of the consideration of reasonably available alternatives. The staff believes documentation demonstrating that the financial professional considered reasonably available alternatives can be particularly important where a recommendation may seem inconsistent with a retail investor’s investment objectives on its face and/or poses conflicts of interest for the firm or the financial professional.[1] As seen in the foregoing SEC staff bulletin, documentation of the due diligence undertaken is, at a minimum, a best practice for investment advisers, and perhaps essential to demonstrate compliance with the investment adviser’s duty of care obligations. [Emphasis added.]
[1] Staff Bulletin: Standards of Conduct for Broker-Dealers and Investment Advisers Care Obligations (April 23, 2023).
This page represents the personal views of Ron A. Rhoades, JD, CFP®, and does not necessarily reflect the views of any institution, firm, organization, motley crew of pirates, cult, or gang, to which Ron has ever belonged to or ever been kicked out of.
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