Broker Check

We are Fiduciaries

We are fiduciaries. We will always act with honesty, integrity, and competence, and diligence.

The fiduciary standard was established as part of the Investment Advisers Act of 1940. It states that an advisor must always act in the best interests of his or her clients and place clients' best interests before his or her own. It also means that an advisor must make sure to provide financial advice that is sound, accurate, and free from conflicts of interest. Furthermore, fiduciaries are required to disclose any potential conflicts of interest to their clients, and must strive to transact on behalf of clients in a manner that's as efficient and low-cost as possible.

Our primary relationship managers, and many staff, are CFP® professionals (Certified Financial Planner). In addition to the fiduciary standard of care for clients required by the Investment Advisors Act, we also abide by the CFP Board’s Code of Ethics and Standards of Conduct. This is a higher level of commitment to our clients.  Violations of the Code and Standards may subject a CFP® professional to discipline. 

CODE OF ETHICS - A CFP® professional must:

  • Act with honesty, integrity, competence, and diligence.
  • Act in the client’s best interests.
  • Exercise due care.
  • Avoid or disclose and manage conflicts of interest.
  • Maintain the confidentiality and protect the privacy of client information.
  • Act in a manner that reflects positively on the financial planning profession and CFP® certification.




At all times when providing Financial Advice to a Client, a CFP® professional must act as a fiduciary, and therefore, act in the best interests of the Client. The following duties must be fulfilled:

        1. Duty of Loyalty. A CFP® professional must:
          1. Place the interests of the Client above the interests of the CFP® professional and the CFP® Professional’s Firm;
          2. Avoid Conflicts of Interest, or fully disclose Material Conflicts of Interest to the Client, obtain the Client’s informed consent, and properly manage the conflict; and
          3. Act without regard to the financial or other interests of the CFP® professional, the CFP® Professional’s Firm, or any individual or entity other than the Client, which means that a CFP® professional acting under a Conflict of Interest continues to have a duty to act in the best interests of the Client and place the Client’s interests above the CFP® professional’s.
        2. Duty of Care. A CFP® professional must act with the care, skill, prudence, and diligence that a prudent professional would exercise in light of the Client’s goals, risk tolerance, objectives, and financial and personal circumstances.
        3. Duty to Follow Client Instructions. A CFP® professional must comply with all objectives, policies, restrictions, and other terms of the Engagement and all reasonable and lawful directions of the Client.


        1. A CFP® professional must perform Professional Services with integrity. Integrity demands honesty and candor, which may not be subordinated to personal gain or advantage. Allowance may be made for innocent error and legitimate differences of opinion, but integrity cannot co-exist with deceit or subordination of principle.
        2. A CFP® professional may not, directly or indirectly, in the conduct of Professional Services:
          1. Employ any device, scheme, or artifice to defraud;
          2. Make any untrue statement of a material fact or omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading; or
          3. Engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person.


A CFP® professional must provide Professional Services with competence, which means with relevant knowledge and skill to apply that knowledge. When the CFP® professional is not sufficiently competent in a particular area to provide the Professional Services required under the Engagement, the CFP® professional must gain competence, obtain the assistance of a competent professional, limit or terminate the Engagement, and/or refer the Client to a competent professional. The CFP® professional shall describe to the Client any requested Professional Services that the CFP® professional will not be providing.


A CFP® professional must provide Professional Services, including responding to reasonable Client inquiries, in a timely and thorough manner.


        1. Disclose Conflicts. When providing FinancialAdvice, a CFP® professional must make full disclosure of all Material Conflicts of Interest with the CFP® professional’s Client that could affect the professional relationship. This obligation requires the CFP® professional to provide the Client with sufficiently specific facts so that a reasonable Client would be able to understand the CFP® professional’s Material Conflicts of Interest and the business practices that give rise to the conflicts, and give informed consent to such conflicts or reject them. A sincere belief by a CFP® professional with a Material Conflict of Interest that he or she is acting in the best interests of the Client is insufficient to excuse failure to make full disclosure.
          1. A CFP® professional must make full disclosure and obtain the consent of the Client before providing any Financial Advice regarding which the CFP® professional has a Material Conflict of Interest.
          2. In determining whether the disclosure about a Material Conflict of Interest provided to the Client was sufficient to infer that a Client has consented to a Material Conflict of Interest, CFP Board will evaluate whether a reasonable Client receiving the disclosure would have understood the conflict and how it could affect the advice the Client will receive from the CFP® professional. The greater the potential harm the conflict presents to the Client, and the more significantly a business practice that gives rise to the conflict departs from commonly accepted practices among CFP® professionals, the less likely it is that CFP Board will infer informed consent absent clear evidence of informed consent. Ambiguity in the disclosure provided to the Client will be interpreted in favor of the Client.
          3. Evidence of oral disclosure of a conflict will be given such weight as CFP Board in its judgment deems appropriate. Written consent to a conflict is not required.
        2. Manage Conflicts. A CFP® professional must adopt and follow business practices reasonably designed to prevent Material Conflicts of Interest from compromising the CFP® professional’s ability to act in the Client’s best interests.


A CFP® professional must exercise professional judgment on behalf of the Client that is not subordinated to the interest of the CFP® professional or others. A CFP® professional may not solicit or accept any gift, gratuity, entertainment, non-cash compensation, or other consideration that reasonably could be expected to compromise the CFP® professional’s objectivity.


A CFP® professional must treat Clients, prospective Clients, fellow professionals, and others with dignity, courtesy, and respect.


        1. A CFP® professional must comply with the laws, rules, and regulations governing Professional Services.
        2. A CFP® professional may not intentionally or recklessly participate or assist in another person’s violation of these Standards or the laws, rules, or regulations governing Professional Services.


        1. A CFP® professional must keep confidential and may not disclose any non-public personal information about any prospective, current, or former Client (“client”), except that the CFP® professional may disclose information:
          1. For ordinary business purposes:
            1. With the client’s consent, so long as the client has not withdrawn the consent;
            2. To a CFP® Professional’s Firm or other persons with whom the CFP® professional is providing services to or for the client, when necessary to perform those services;
            3. As necessary to provide information to the CFP® professional’s attorneys, accountants, and auditors; and
            4. To a person acting in a representative capacity on behalf of the client;
          2. For legal and enforcement purposes:
            1. To law enforcement authorities concerning suspected unlawful activities, to the extent permitted by the law;
            2. As required to comply with federal, state, or local law;
            3. As required to comply with a properly authorized civil, criminal, or regulatory investigation or examination, or subpoena or summons, by a governmental authority;
            4. As necessary to defend against allegations of wrongdoing made by a governmental authority;
            5. As necessary to present a civil claim against, or defend against a civil claim raised by, a client;
            6. As required to comply with a request from CFP Board concerning an investigation or adjudication; and
            7. As necessary to provide information to professional organizations that are assessing the CFP® professional’s compliance with professional standards.
        2. A CFP® professional may not use any non-public personal information about a client for his or her direct or indirect personal benefit, whether or not it causes detriment to the client, unless the client consents.
        3. A CFP® professional, either directly or through the CFP® Professional’s Firm, must take reasonable steps to protect the security of non-public personal information about any client, including the security of information stored physically or electronically, from unauthorized access that could result in harm or inconvenience to the client.
        4. A CFP® professional, either directly or through the CFP® Professional’s Firm, must adopt and implement policies regarding the protection, handling, and sharing of a client’s non-public personal information and must provide a client with written notice of those policies at the time of the Engagement and thereafter not less than annually (at least once in any 12-month period) unless (i) the CFP® professional’s policies have not changed since the last notice sent to a client; and (ii) the CFP® professional does not disclose non-public personal information other than as permitted without a client’s consent.
        5. A CFP® professional shall be deemed to comply with this Section if the CFP® Professional’s Firm is subject to, and the CFP® professional complies with, Regulation S-P under the federal securities laws or substantially equivalent federal or state laws or rules.


        1. When Providing Financial Advice. When providing or agreeing to provide Financial Advice that does not require Financial Planning in accordance with the Practice Standards, a CFP® professional must provide the following information to the Client, prior to or at the time of the Engagement, and document that the information has been provided to the Client:
          1. A description of the services and products to be provided;
          2. How the Client pays for the products and services, and a description of the additional types of costs that the Client may incur, including product management fees, surrender charges, and sales loads;
          3. How the CFP® professional, the CFP® Professional’s Firm, and any Related Party are compensated for providing the products and services;
          4. The existence of any public discipline or bankruptcy, and the location(s), if any, of the webpages of all relevant public websites of any governmental authority, self-regulatory organization, or professional organization that sets forth the CFP® professional’s public disciplinary history or any personal bankruptcy or business bankruptcy where the CFP® professional was a Control Person;
          5. The information required under Section A.5.a. (Conflict of Interest Disclosure);
          6. The information required under Section A.9.d. (Written Notice Regarding Non-Public Personal Information);
          7. The information required under Section A.13.a.ii. (Disclosure of Economic Benefit for Referral or Engagement of Additional Persons); and
          8. Any other information about the CFP® professional or the CFP® Professional’s Firm that is Material to a Client’s decision to engage or continue to engage the CFP® professional or the CFP® Professional’s Firm.
        2. When Providing Financial Planning. When providing or required to provide Financial Planning in accordance with the Practice Standards, a CFP® professional must provide the following information to the Client, prior to or at the time of the Engagement, in one or more written documents:
          1. The information required to be provided in Sections A.10.a.i.-iv. and vi.-viii.; and
          2. The terms of the Engagement between the Client and the CFP® professional or the CFP® Professional’s Firm, including the Scope of Engagement and any limitations, the period(s) during which the services will be provided, and the Client’s responsibilities. A CFP® professional is responsible for implementing, monitoring, and updating the Financial Planning recommendation(s) unless specifically excluded from the Scope of Engagement.
        3. Updating Information. A CFP® professional has an ongoing obligation to provide to the Client any information that is a Material change or update to the information required to be provided to the Client. Material changes and updates to public disciplinary history or bankruptcy information must be disclosed to the Client within ninety (90) days, together with the location(s) of the relevant webpages.


A CFP® professional must provide a Client with accurate information, in accordance with the Engagement, and in response to reasonable Client requests, in a manner and format that a Client reasonably may be expected to understand.


A CFP® professional may not make false or misleading representations regarding the CFP® professional’s or the CFP® Professional’s Firm’s method(s) of compensation.

        1. Specific Representations
          1. Fee-Only. A CFP® professional may represent his or her or the CFP® Professional’s Firm’s compensation method as “fee-only” only if:
            1. The CFP® professional and the CFP® Professional’s Firm receive no Sales-Related Compensation; and
            2. Related Parties receive no Sales-Related Compensation in connection with any Professional Services the CFP® professional or the CFP® Professional’s Firm provides to Clients.
          2. Fee-Based. CFP Board uses the term “fee and commission” to describe the compensation method of those who receive both fees and Sales-Related Compensation. A CFP® professional who represents that his or her or the CFP® Professional’s Firm’s compensation method is “fee- based” or any other similar term that is not fee-only:
            1. May not use the term in a manner that suggests the CFP® professional or the CFP® Professional’s Firm is fee-only; and
            2. Must clearly state that either the CFP® professional or the CFP® Professional’s Firm earns fees and commissions, or that the CFP® professional or the CFP® Professional’s Firm are not fee- only.
          3. Sales-Related Compensation. Sales-Related Compensation is more than a de minimis economic benefit, including any bonus or portion of compensation, resulting from a Client purchasing or selling Financial Assets, from a Client holding Financial Assets for purposes other than receiving Financial Advice, or from the referral of a Client to any person or entity other than the CFP® Professional’s Firm. Sales-Related Compensation includes, for example, commissions, trailing commissions, 12b-1 fees, spreads, transaction fees, revenue sharing, referral or solicitor fees, or similar consideration. Sales-Related Compensation does not include:
            1. Soft dollars (any research or other benefits received in connection with Client brokerage that qualifies for the “safe harbor” of Section 28(e) of the Securities Exchange Act of 1934);
            2. Reasonable and customary fees for custodial or similar administrative services if the fee or amount of the fee is not determined based on the amount or value of Client transactions; 
            3. Non-monetary benefits provided by another service provider, including a custodian, that benefit the CFP® professional’s Clients by improving the CFP® professional’s delivery of Professional Services, and that are not determined based on the amount or value of Client transactions;
            4. Reasonable and customary fees for Professional Services, other than for solicitations and referrals, the CFP® professional or CFP® Professional’s Firm provides to a Client that are collected and distributed by another service provider, including under a Turnkey Asset Management Platform; or
            5. A fee the Related Party solicitor receives for soliciting clients for the CFP® professional or the CFP® Professional’s Firm.
          4. Related Party. A person or business entity (including a trust) whose receipt of Sales-Related Compensation a reasonable CFP® professional would view as directly or indirectly benefiting the CFP® professional or the CFP® Professional’s Firm, including, for example, as a result of the CFP® professional’s ownership stake in the business entity. There is a rebuttable presumption that a Related Party includes:
            1. Family Members. A member of the CFP® professional’s Family and any business entity that the Family or members of the Family Control; and
            2. Business Entities. A business entity that the CFP® professional or the CFP® Professional’s Firm Controls, or that is Controlled by or is under common Control with, the CFP® Professional’s Firm.
          5. In Connection with any Professional Services. Sales-Related Compensation received by a Related Party is “in connection with any Professional Services” if it results, directly or indirectly, from Client transactions referred or facilitated by the CFP® professional or the CFP® Professional’s Firm.
          6. Safe Harbor for Related Parties. Sales-Related Compensation received by a Related Party is not “in connection with any Professional Services” if the CFP® professional or the CFP® Professional’s Firm adopts and implements policies and procedures reasonably designed to prevent the CFP® professional or the CFP® Professional’s Firm from recommending that any Client purchase Financial Assets from or through, or refer any Clients to, the Related Party.
          7. Misrepresentations by a CFP® Professional’s Firm. A CFP® professional who Controls the CFP® Professional’s Firm may not allow the CFP® Professional’s Firm to make a representation of compensation method that would be false or misleading if made by the CFP® professional. A CFP® professional who does not Control the CFP® Professional’s Firm must correct a CFP® Professional’s Firm’s misrepresentations of compensation method by accurately representing the CFP® professional’s compensation method to the CFP® professional’s Clients.


        1. When engaging or recommending the selection or retention of additional persons to provide financial or Professional Services for a Client, a CFP® professional must:
          1. Have a reasonable basis for the recommendation or Engagement based on the person’s reputation, experience, and qualifications;
          2. Disclose to the Client, at the time of the recommendation or prior to the Engagement, any arrangement by which someone who is not the Client will compensate or provide some other material economic benefit to the CFP® professional, the CFP® Professional’s Firm, or a Related Party for the recommendation or Engagement; and
          3. When engaging a person to provide services for a Client, exercise reasonable care to protect the Client’s interests.
        2. When working with another financial or Professional Services provider on behalf of a Client, a CFP® professional must:
          1. Communicate with the other provider about the scope of their respective services and the allocation of responsibility between them; and
          2. Inform the Client in a timely manner if the CFP® professional has a reasonable belief that the other provider’s services were not performed in accordance with the scope of services to be provided and the allocation of responsibilities.


        1. A CFP® professional must exercise reasonable care and judgment when selecting, using, or recommending any software, digital advice tool, or other technology while providing Professional Services to a Client.
        2. A CFP® professional must have a reasonable level of understanding of the assumptions and outcomes of the technology employed.
        3. A CFP® professional must have a reasonable basis for believing that the technology produces reliable, objective, and appropriate outcomes.


      1. A CFP® professional may not, directly or indirectly, borrow money from or lend money to a Client unless:
        1. The Client is a member of the CFP® professional’s Family; or
        2. The lender is a business organization or legal entity in the business of lending money.
      2. A CFP® professional may not commingle a Client’s Financial Assets with the Financial Assets of the CFP® professional or the CFP® Professional’s Firm.

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