Solicitor Policy and Procedure

Overview

SEC-registered investment advisers may allow the use of solicitors to introduce prospective clients, in compliance with SEC Rule 206(4)-1 under the Investment Advisers Act of 1940.

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Solicitor arrangements are subject to heightened scrutiny by the SEC and are a frequent focus of regulatory audits and exams. To protect all parties involved — Clients, ourselves as IARs, Core Planning, and our solicitors — we follow a structured process that’s simple and minimal, but also mirrors legal requirements and ensures we remain in full compliance.

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Definition

A "solicitor" is defined as any individual or entity who is compensated directly or indirectly for introducing clients or prospective clients to Core Planning.

Policy and Procedure Steps

Step 1: Eligibility and Approval

• Solicitors must be appropriately qualified and compliant with SEC rules (as are outlined in Rule 206(4)-1 and tied to Rule 506(d) of Regulation D.)

This means they cannot be subject to disqualifying events, including:

• SEC or other regulatory bars or suspensions
• Felony convictions related to financial services
• Certain court injunctions