How to Get Around Broker Dealer Compliance if They Don't Approve of our Money Management Systems
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As you may know, most investing strategy your BD wants you to use usually ends up getting lousy investment performance. Especially if you hire their outside "money managers."
Keep in mind that if you use a third-party money manager, and they charge 50bps, then for every million you have with them, you're giving up $50,000 a year of gross income. Our investing system allows you to keep all of your money, while most likely realizing better returns with less risk.
So if you're interested in using our Models, asset allocation software (and/or the mutual fund selections), but think your Broker Dealer won't approve it; there's still hope.
If they don't approve it, then here's what you can do:
Gather the client data needed for input into the software using any investment fact finder that's approved. Print it and keep it on file.
Then use our investment software (and/or investing questionnaire) at home on a non-work computer and write the bottom-line trades down after doing the work.
When you get back to the office, just make the trades and manage the portfolio as usual.
Just don't show, print, nor give any of the reports to anyone. Don't tell anybody, don't put anything in their paper or computer file (at home or at work), and nobody will ever know what system you're using.
You'll get the same results as if everyone had hard copies.
Basically, if you're not telling or showing clients your system, then it doesn't need to be approved. This is because you're "not communicating" anything to the public, and only "communications, sales literature, or advertisements" need to be approved.
If you're not communicating anything, then there's nothing to be approved.
If you're not using a system, then it doesn't need to be approved.
So if you keep it all a secret, then nobody can prove you're using an "unapproved system."
Then even if they do, you're not breaking any rules, because you never communicated any non-approved material to anyone.
The irony is that a BD Rep is allowed to just wing it (create and implement investment portfolios) at random ad hoc, with no clue, system, communications, strategy nor plan at all according to BD compliance and Finra.
Yes, managing money for clients without a clue is perfectly legal for BD Reps, and happens about 75% of the time.
So this is what you'll appear to be doing - the same old random ad hoc thing everyone else is doing with client moneys.
So just tell others you're winging it on intuition, and nobody can do nor say anything about it.
What you're doing is telling others you're not using any system at all, and then you can use these asset allocator software programs to do the actual work, everyone will be happy, and only you will ever know. It works great.
Everyone will think you're a genius and will wonder how you're doing it. Just tell them you use a little of this and a little of that and you're a good mutual fund picker.
This is the same generic investor strategy everyone else is using anyway, so they'll think you're doing the same thing, but are just better at it.
If colleagues ask you to show or train them on what you're doing, just say no.
The only difference is that clients won't have printed reports. If what you're limited to using doesn't have printed reports of value anyway, then they won't be missing anything.
This way you can get the low risk and good returns by funding a pure asset allocation strategy with mutual funds, and you'll minimize the whole compliance annoyance and/or getting into trouble (for doing good things for clients for a change).
You can then input Current and Proposed portfolio data into Morningstar if you want to give or show clients approved reports (AKA approved fund detail pages).
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