Policy & Procedure Manual for Sponsor IARs

Purpose of This Guide

Your role is essential in maintaining our culture of compliance, transparency, and client care.

While your support team members may be paid directly from your practice, they are still supervised persons under SEC guidelines and your guidance ensures they operate with integrity inside our fiduciary framework.

Step 1: share details with your access person

[ send this link ]

Step 2: access person onboarding

Part of the workflow in Step 1 involves your access person submitting an onboarding form. We like for this form to be jumpstarted by them as it let’s them take ownership and feel part of the process. But you should guide them through their side of the onboarding.

🔷 Your Role as a Sponsor IAR

A paid support person is paired one-on-one with a licensed Investment Adviser Representative (IAR)—that’s you—who acts as their:

• Supervisor – Defining scope, tasks, and access boundaries
• Gatekeeper – Ensuring their work aligns with firm and regulatory expectations
• Compliance Partner – Monitoring and documenting access and reporting when needed