why we do it

We periodically review a sample of client portfolios as part of our ongoing compliance and supervisory program.

It is a quick, independent check to confirm that:

• we have enough current information about the client
• the overall portfolio appears broadly consistent with that information
• anything unusual has a reasonable and documented explanation

how often we review

Reviews are conducted quarterly.

Each quarter, we’ll generally select:

• 12 advisors
• one household or client relationship per advisor

This results in approximately:

• 12 household reviews per quarter
• 48 household reviews per year

We randomize advisor selection, not client selection because one advisor might have 50 clients and another advisor might have 5 clients. And one advisor should not be 10X more likely to be reviewed.

Advisors are rotated over time to provide broad supervisory coverage across the firm.

We may review additional households when an initial review raises questions or when circumstances suggest that a closer look could be helpful.