Last week, FINRA "conceptualized" what it would be like for broker-dealers to provide ADV-like disclosures to retail customers.  [scroll to RULE Blog 10/27]  Dan Jamieson of InvestmentNews wrote about it, though mostly to the negatives.  C-I sees 4 positive disclosures in the ADV that would be relevant and helpful.  Read on.  For complete details, click onto:   [ Form ADV, on sec.gov ]

    1.  World Wide Web site addresses?   If ”yes,” list these addresses, and if a web address serves as a portal through which to access other information you have published on the WWW, you may list the portal without listing addresses for all of the other information.

    2.  Compensation Arrangements.   How firm is compensated for services (check all that apply):

(i) A percentage of assets under your management  .....  (ii) Hourly charges  .....  (iii) Subscription fees (newsletter, periodical)  .....  (iv) Fixed fees (other than subscription fees)  .....  (v) Commissions  .....  (vi) Performance-based fees.

    3.  Assets Under Management.   A firm's client or customer base, say categorized by type, numbers, total $ amount. Also, an explanation for how firm calculated the figures. 

    Financial Industry Affiliations.  In this Item, firm asked about financial industry affiliations and activities - to ID areas in which conflicts of interest may occur between firms and clients.  This section requires on both the firm and its related persons - i.e., all of firm's advisory affiliates and any person that's under common control with the firm.

    3.  Participation or Interest in Client Transactions.  In this Item, firm asked to provide info about its participation and interest in its clients’ transactions.  This information ID's areas in which conflicts of interest may occur between firm and clients.  Examples: 

(i) Proprietary Interest in Client Transactions  .....  (ii) Sales Interest in Client Transactions  .....  (iii) Investment or Brokerage Discretion.

To continue, click onto:   [ Form ADV on sec.gov ]