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How to Draw the Bright Line Between RIA Fiduciaries and Product Pushing, Conflicted Competitors

By Kathleen M. McBride, AIFA®

As hundreds of RIAs gather in Boston for Schwab’s IMPACT 2015, the news that some Congressional Democrats are joining Republicans in an effort to head off the administration’s fiduciary rule on retirement accounts underscores a political reality: broker-dealers, banks, insurance companies and mutual fund companies still wield enormous influence in Washington.

The brokers, banks, insurers and mutual fund companies will spare no expense to win regulatory cover allowing them to assert claims – however unfounded – that they, too, act in their customers’ best interest.  They will continue to spend millions to destroy or dilute the impact of the DOL fiduciary rules and head off or cripple similar regulatory initiatives at the federal and state level.  This fight will likely continue into the next Congress and administration, as well as in the courts.

As a result, efforts to strengthen fiduciary obligations of brokers and insurance reps will make progress but the regulatory outcome will fall far short of perfection.  The distinction between the fiduciary standard and suitability will get even fuzzier.  Dual registration will continue to confuse and confound clients.

What does this mean for RIAs?

First, RIAs cannot count on the regulators to draw a bright line between RIAs’ client-focused business model and that of their product-pushing, conflicted competitors. More than ever, RIAs will have to lean into differentiating and validating their firms’ commitment to fiduciary excellence.

Second, some forward-thinking competitors – among brokers, banks, insurance companies and mutual fund companies, are already working to build a more fiduciary culture and appropriate product offerings and compensation models.  Instead of a race to the lower standard, we may have an outbreak of higher standards among some key competitors.

The good news is that the national debate on this issue has shined a light on the value of working with a true fiduciary.  We know the fiduciary model works – for both clients and firms.  There’s already evidence that prospective clients are asking about firms’ standing as fiduciaries.

In this environment, RIAs have an opportunity to distinguish themselves and build their practices.  If you’d like to talk about how to achieve that goal, please come by Booth 144 at IMPACT, where I can be found with my colleagues from the Centre for Fiduciary Excellence – CEFEX – and fi360.

Kate McBride, AIFA®, founder of FiduciaryPath, LLC is an Accredited Investment Fiduciary Analyst®; a CEFEX analyst with the Centre for Fiduciary Excellence, auditing fiduciary firms’ investment fiduciary practices for certification; and a consultant on fiduciary matters. Ms. McBride serves as chair of The Committee for the Fiduciary Standardkmcbride@fiduciarypath.com.

5 Ways Top RIA Firms Help Clients When Markets Are Challenging

By Kathleen M. McBride, AIFA®

When market volatility like the swings we’ve seen last quarter make clients uneasy, fiduciaries that have a framework of prudent fiduciary practices in place, can call on them to help ease clients’ fears and mitigate the risk of unhappy clients later.

As a CEFEX analyst, I get invited in to audit RIA firms’ investment fiduciary practices for certification by the Centre for Fiduciary Excellence.  Elite RIA firms that earn peer-reviewed CEFEX Certification, achieve public recognition for their investment fiduciary excellence, a very important differentiator for clients. CEFEX Certified firms grow faster – nearly twice as fast as non-certified RIA firms.

Certification is also a chance for firms to see where they have opportunities for improvement, or uncover a gap  – a risk that the firm can address now, before it causes a problem.

Here are a handful of the prudent practices I see at firms that have earned CEFEX Certification. The prudent practices are outlined in the handbook, “Prudent Practices for Investment Advisors,” available at www.fi360.com, and substantiated with discussions of regulation and law.  The basic framework forms a four-part circle: Organize, Formalize, Implement and Monitor.

On days when clients need their advisers most, a few simple prudent practices can make all the difference for client and adviser.

Elite, certified firms make sure clients are set for both tranquil and challenging markets:

  1. They already have a written, signed agreement and Investment Policy Statement (IPS) for each client, that discusses the client’s time horizon, risk tolerance, objectives, appropriate asset allocation and monitoring and replacement criteria.
  2. They keep these in client’s files, along with implementation notes and monitoring reports with review notes.
  3. Their clients’ portfolios are diversified, according to each one’s signed IPS.
  4. The portfolios are implemented with appropriate asset allocation (and documented) expertise, skill and due diligence, according to their IPS.
  5. They conduct regular portfolio reviews, to monitor investment performance and costs against appropriate peers and indexes, rebalance on a regular basis according to their criteria, and replace when necessary.

In times of market stress, they can help clients keep calm and carry on:

  • They stay in touch as many clients as possible via email, phone, or announcement.  These can be very straightforward conversations, such as:  “In accordance with your IPS, we’ve diversified your portfolio so that when some assets like equities are volatile, others will normally be more stable. You are appropriately allocated across asset types, in line with the IPS. This gives you your best chance for success over the long term. What is on your mind?”
  • When speaking or emailing with individual clients, they make sure to document what they’ve discussed, when, any decisions or next steps, and why. Certified RIA firms keep brief notes, reports and other documentation in the client’s file so if there’s any question later they can refer to the time, place circumstances, recommendations and any next steps.
  • These client notes can be short – but they are very important, especially if a client forgets what’s been discussed, recommended, and why:
  • SW Sue Brown re her jt act w Ted, they have long time horizon; advised no change right now & will touch base on next steps in 1-2 weeks (sooner if necessary).
  • SW Bob Jones, wanted to go to cash; discussed his IPS, noted he has some cash for immediate needs and we may want to make some rebalancing adjustments to his portfolio as the dust settles, but recommended not doing that today. He agreed to sit tight a few days. Advised I will check in next wk, and to call me if needs to speak sooner.
  • Dr. Jo Boone noted that some of the individual stocks in her mad money account were a concern – that’s the account she directs on her own, which I reminded her. She wanted to trim there, but not necessarily in her other portfolios we manage.  When I asked if she needed the cash from the self-directed account right away, she noted there’s an estimated tax pmt in 2 wks; I noted there’s a position she could harvest to offset some gains, and she wants to go ahead.  Order sent to trading.

RIA firms that have prudent practices in place build trust with clients because they deserve that trust. When they make the effort to have an independent, third party come in and verify that for clients, it is very meaningful for clients and prospective clients.  When an RIA firm has a well-thought-out, repeatable set of practices in place, clients are better served, the firm is better managed, and has more control over all operations, from client acquisition to investment management or manager selection, to compliance, back office and cyber security.  When firms are well managed, they keep more revenue, and tend to have better client outcomes over the long term.

And when markets get challenging, they are set to help clients get through them.

Kate McBride, AIFA®, founder of FiduciaryPath, LLC is an Accredited Investment Fiduciary Analyst®; a CEFEX analyst with the Centre for Fiduciary Excellence, auditing fiduciary firms’ investment fiduciary practices for certification; and a consultant on fiduciary matters. Ms. McBride serves as chair of The Committee for the Fiduciary Standardkmcbride@fiduciarypath.com.

Can Advise(o)rs Disclose Away Their Fiduciary Obligations?

Disclosure and its role in the advisory relationship became a major focus of panelists at a recent New York Society of Security Analysts/CFA Institute forum on “Wall Street’s Excesses: Bad Behavior and Over-Regulation.”  The topic surfaced in the first panel on enforcement, when the question was raised, “Can an advisor ‘disclose away’ her or his fiduciary obligations simply by surfacing all conflicts and fees?”

Blaine Aikin, chief executive officer of fi360 and a CFP board member, took up the question on our panel on the fiduciary standard: “The answer to the question can you disclose away a fiduciary obligation is that the devil is in the ‘can you?’  You could probably escape punishment, but is it acceptable under the fiduciary standard to ‘disclose away’ a fiduciary duty.  The answer is clearly ‘no.’”

“Disclosure is not a substitute for fulfillment of the duties of loyalty and care.  We have gaping holes in the way that the law is enforced today. [That’s why upholding professional standards] becomes a critical function for organizations like the CFA Institute and the CFB Board.”

“With the CFP Board, you have a disciplinary process that brings [certificate holders] before professionals in the field. If you have people who are well informed in terms of the obligations that are involved – which you do in the disciplinary process of the CFP board – then you apply those standards in a way that understands that you can’t ‘disclose away’ professional liability.”

For my part, I noted studies by such leading academics as Prof. Daylian Cain at Yale School of Management, which indicate that disclosures can have a perverse effect.

According to Prof. Cain’s research, when an advise/or makes a disclosure to an investor – even a well-meaning advise/or – the investor feels more confident that the advise/or is being forthright and is thus less likely to question that advice.  Moreover, the advise/or is more likely to give more aggressive advice that may tilt more to the advisor’s interests than those of the investor.

Bottom line: Disclosure and transparency are important but certainly no substitute for holding all advise/ors – registered reps, insurance agents and RIAs – to a strong fiduciary standard of care.

Kate McBride, AIFA®, founder of FiduciaryPath, LLC is an Accredited Investment Fiduciary Analyst®; a CEFEX analyst with the Centre for Fiduciary Excellence, auditing fiduciary firms’ investment fiduciary practices for certification; and a consultant on fiduciary matters. Ms. McBride serves as chair of The Committee for the Fiduciary Standardkmcbride@fiduciarypath.com.

About Face: AOL’s 401(k) Match Mistake

Tim Armstrong’s recent decision to defer AOL’s 401(k) employer match contributions until year-end was alarming enough. Blaming that change on the expense of healthcare costs to treat employees’ seriously ill babies demonstrated stunning lapses in judgment and serious flaws in leadership. One wonders who is advising AOL’s CEO and what led to these blunders.

The good news is that public outcry apparently led AOL to reverse its decision to defer match contributions until year-end. AOL’s company match contributions will be made as they had been, at each payroll.  Here we visit the 401(k) match deferral and the problems caused by a downgrade of benefits – for that’s what deferring the match would be.  

Research shows that the way companies structure their 401(k) plans makes a material difference in employee savings rates, and can enhance or detract from retirement participant outcomes. The goal, of course, is having enough money to retire.

Employers can influence employees to save more for retirement by optimizing how they match employee contributions; using automatic enrollment and escalation of savings rates over time; and ensuring that fees paid by the plan and its participants are reasonable, according to research from National Bureau of Economic Research, Harvard, AON Hewitt, Employee Benefit Research Institute, the Society for Human Resource Management and the Department of Labor. 

Sponsoring a 401(k) plan and the company match for a 401(k) plan is voluntary. For many companies a defined contribution 401(k) plan is also a way to relieve the company of the pension liability burden they held when defined benefit pension plans were the norm, and guaranteed an income for life for retired employees. At that time, ERISA 401(k) plans were a supplemental savings vehicle, for employees who wanted to save more for retirement.  Now, defined contribution 401(k) plans are the primary retirement savings vehicle.  As such, they shift retirement risk away from the company, to the employee. 

AOL’s effort to change to its employee matching contribution to year-end is a way to slash benefits that would rob employees of important retirement savings advantages: the compounding effect of the match being contributed regularly throughout the year, the advantage of dollar-cost-averaging, and the beneficial behavioral effects of the periodic company match boosting employee contributions.  There’s also the issue of whether the match would be paid at all if an employee left before year-end.

Most companies, “about 71%, match each payroll,” while about 12% “match monthly or quarterly,” according to San Francisco Chronicle columnist Kathleen Pender, in an article entitled “401(k) match at year-end can undermine benefit.

Pender mentions that though only 17% of firms match only at year-end, “Charles Schwab – one of the top 401(k) plan administrators - Morgan Stanley, JPMorgan Chase and Deutsche Bank all have this policy.” 

AOL’s decision to reinstate the match with every paycheck is in the best interest of AOL employees who participate in the 401(k).  It is a better choice.  We hope the dialogue will inspire other companies to step up to the every-payroll company match and look at the research that indicates what other steps companies can take to help employees maximize their retirement savings. — Kathleen M. McBride

For more, please see the research and resources below:

National Bureau of Economic Research –  EMPLOYER MATCHING AND 401(K) SAVING: EVIDENCE FROM THE HEALTH AND RETIREMENT STUDY – Gary V. Engelhardt, Anil Kumar  http://www.nber.org/papers/w12447.pdf 

Harvard University – Saving For Retirement on the Path of Least Resistance — James J. Choi, Harvard University; David Laibson, Harvard University and NBER; Brigitte C. Madrian, University of Chicago and NBER; Andrew Metrick, University of Pennsylvania and NBER  http://www.nber.org/programs/ag/rrc/04-08LaibsonFinal.pdf 

AON Hewitt – 2013 Trends & Experience in Defined Contribution Plans – An Evolving Retirement Landscape  http://www.aon.com/attachments/human-capital-consulting/2013_report_Trends-Experience-DC-Plans_Highlights.pdf

Department of Labor – A look at 401(k) Plan Fees  http://www.dol.gov/ebsa/publications/401k_employee.html 

Employee Benefit Research Institute  http://www.ebri.org/research/retirement-research-centers/

Society for Human Resource Management  http://www.shrm.org/hrdisciplines/benefits/articles/pages/match-thresholds.aspx

Fiduciary Weekend Round Up 1.25.14

Fiduciary Weekend Round Up

Does SIFMA Seek to Protect Model Where Client Serves the Broker, Not Fiduciary Model Where Broker Protects the Client?

Fiduciary News’s exclusive interview with Kate McBride, by Chris Carosa



Wall Street’s Whipping Boy and a World Without a Fiduciary Standard

Fiduciary News’s Fiduciary Crystal Ball 2014 – with Fiduciary Ron Rhoades and more



Worth Reading: “Keynes’s Way to Wealth” by John Wasik

Many think of John Maynard Keynes as the father of macroeconomics. What may surprise is Keynes’s success as in investor for himself, family and friends, and institutions.



Nobel Laureate Robert Shiller talks with Kate McBride –Podcast Replay

Interviewed amidst the economic crisis, Prof. Shiller discusses Keynes’s “Animal Spirits” and more. His words and forecast hold up, with much still playing out.



Brokers as Fiduciaries?

This white paper by Andrew Clipper raises interesting challenges for fiduciaries and those who want to be.


The $14 Trillion Question: Why Aren’t There More Bidding Wars for Service Providers to 401(k) Plans?

 By Kathleen M. McBride, Sept 5, 2013

This may be the questions more employers who sponsor 401(k) pension plans ask in the coming months after some 6,000 of them received letters advising them that the plans they sponsor appear to have higher-than-average costs. Higher costs can drag down the amount of savings that is left for the investor after fees are paid.

Over a lifetime of retirement savings, higher costs can deduct hundreds of thousands of dollars from the investor and put them in the pocket of individuals and firms that provide services to the plan.

Alarming? Sure. Important? You bet. The hope for a dignified retirement for millions of Americans hangs in the balance.

Recently, Yale Law Prof. Ian Ayres sent letters to 6,000 pension plans, alerting them that their plan’s fees and expenses register higher than average in a study.  University of Virginia School of Law Prof Quinn Curtis, and Prof Ayers conducted the study, entitled “Measuring Fiduciary and Investor Losses in 401 k Plans.

The study measures what the professors call “fiduciary losses” and “investor losses.”

Fiduciary losses relate to the plan’s expenses, and the limited menu of investments that employees who participate in the 401(k) can choose from (often a selection of mutual funds). These are under the control of the employer who sponsors the plan (the fiduciary).

Investor losses relate to how plan participants – investors – choose the investments from the limited menu that is offered in the plan.

Many investor advocates are concerned about high fees in 401(k)s, which started as a way of subsidizing traditional pensions, and now have become the centerpiece of American’s retirement system.

The firms, brokers and advisors who provide services to 401(k) plans say the higher fees are justified because of the services that are provided.

But why do some plans have costs that are many times higher than others? Are services that different?

Lack of Transparency

Until recently there it was nearly impossible to get a clear, detailed understanding of the costs 401(k) plans and participating investors pay for investments, recordkeeping, administration and other services. The Department of Labor has been changing that, with new requirements that mandate disclosure of fees to plan sponsors – and participants in the plans.

Plan sponsors are fiduciaries and must “act prudently and loyally to participants,” says Jeffrey Turner, Deputy Director, Regulations and Interpretations, EBSA, Department of Labor.

On a call to discuss “401K Fees And Expenses And Plan Sponsor Fiduciary Duties,” hosted by the Institute for the Fiduciary Standard, Turner noted that plan sponsors must act solely in the best interest of plan participants when selecting investment options, service providers and monitoring their choices regularly – and documenting the choices they make and how they arrived at those choices, as fiduciaries.

ERISA “forbids overpayments from plan assets,” Turner says.  Plan fiduciaries should pay “not more than reasonable fees” to the service providers they select. They must also obtain “information sufficient to enable informed decisions,” including information on costs.

But how do plan sponsors know whether the fees they pay are “reasonable?” Is there a way for participants to compare 401(k) plan costs?  

John Rekenthaler, Vice President of Research at Morningstar says, “It took years for investors to change their buying habits for mutual funds,” once they started to see information on costs and performance from data gathered by Morningstar. It’s more complex to gather the fee information from 401(k) plans, he But he’s optimistic – “it’s going to be done – it’s difficult to get all the information from the outside” of the plans. 

Benchmarking 401(k) Plans


Benchmarking is one resource that’s widely used and has an important role, but it can be tricky. Edward Lynch, Founder & CEO of Fiduciary Plan Governance, LLC, works with pension plan sponsors and notes that for some clients they will “use three benchmarking services and get three different results,” because each benchmarking firms may use different data sets. Sometimes clients “need more than benchmarking.” When that’s the case, putting the plan’s service providers – and advisor(s) – out for competitive bid may be the best way to see what fees are reasonable.

This is done with a “Request for Information” or “Request for Proposal” which basically puts the different services – advisory, administration, record keeping, custody of assets, investment managers and perhaps more, on notice to sharpen their pencils and provide their best bid to get the job providing the services. The RFIs go to many potential providers and the process, like a reverse auction, introduces the plan sponsor to new providers who outline the services to be provided and the costs for the services. Current providers may also bid. Lynch says that this is “so impactful” that he has seen plan costs drop by two-thirds in some cases.  That leaves more in plan investor participant’s retirement accounts.

The light that is shining on 401(k) plans, the prudence with which they are managed, their costs to investors, has been bubbling up for some time, but came to a high boil with the release of the Ayers letters.  Time reporter Christopher Matthews says in an article entitled America Can’t Afford Wall Street’s Terrible Investment Advice: “With a retirement-savings gap that’s been estimated to be as much as $14 trillion, and Washington fighting over how much we need to cut Social Security, the American retirement system simply can’t afford to support an investment industry that makes billions from deliberately confusing its clients and steering them toward expensive products that shrink retirement accounts over time. The fact that the industry admits that it would have to drop the business of lower-income folks if forced to act in their best interest should tell you all you need to know about the value of its advice.”

In an article about the Ayers letters in Forbes, 401(k) Letters Could Expose The Worst Retirement Plans, John Wasik quotes Morningstar’s Rekenthaler: “It’s understandable that the 401(k) marketplace dislikes the letter’s implicit threat. However, such annoyances are part of the deal. The 401(k) plan has given fund companies nearly $3 trillion in incremental assets–$15 billion in annual revenues, assuming an average fund expense ratio of 0.50%. It has permitted corporations to shed the burden of guaranteeing pensions. Those benefits for fund companies and plan sponsors don’t come for nothing. They come with a spotlight. Get used to the glare, people. It will only get brighter.”


Emerging Issue for Investors – What Advisor Titles Mean: Why it’s Critically Important

For investors across all wealth categories, confusion over broker/advisor titles is rampant and material. Why? Because marketing titles like “wealth manager” or “financial advisor” don’t tell investors whether they are dealing with a salesperson or an investment advisor –who always must put the investor’s interests first.

See “Picking the Best Wealth Advisors From the Rest


The potential harm for investors is a political issue, as the SEC and Department of Labor continue work on fiduciary requirements for brokers that are like the fiduciary requirements already in place for investment.  Big bank brokers back Congressional representatives that vote to starve the SEC of funding it already earns, which doesn’t cost taxpayers a dime (but Congress, apportioning the SEC budget, keeps hundreds of millions of dollars the SEC takes in via fees for listing and trading), hoping keep the status quo aka no fiduciary rules for brokers.

What’s the Harm?

If investors, saving for retirement, get advice that is in their broker’s interest, they may pay substantially more in fees and be sold more risky securities, materially harming their chance retirement resources.  A “1 percent difference in fees and expenses would reduce your account balance at retirement by 28 percent,” according to the Dep’t of Labor.

If Congress wants to be able to hold down costs for Social Security, it should overwhelmingly back fiduciary duty for advice to investors, giving investors a better shot at achieving their retirement goals.

Here’s the Most Surprising Finding: 

Most brokers, investment advisors and dually registered advisors (87%) in the field agreed in a recent survey there should be clearer differentiation between product providers and advice providers.

A majority (71%+) say the titles “advisor,” “consultant,” and “planner,” imply that a fiduciary relationship exists.” But that’s frequently not the case.

See Survey Report: Trustworthy Advice: Is the Fiduciary Standard the New Normal for Financial Advisors?


–Kathleen M. McBride

To Increase Revenue Stop Selling

Forbes Contributor Mike Myatt posted an excellent article  entitled, “To Increase Revenue Stop Selling.” Bravo, Mike. Your point is important and holds especially true for financial services. This is a long term thinking vs short term thinking issue as well. And the reasons are practical as well.
Client acquisition is much harder than client retention.  It is much harder to bring in new client than to: put your client’s best interests before your own, avoid conflicts of interest, manage those conflicts you can’t avoind in the client’s best interest, help them diversify their holdings and disclose ALL costs to the investor — than to constantly have to bring in new clients.

In the discussion about extension of the fiduciary standard to brokers who advise individual investors, this is especially important. The antiquated culture at banks, BDs and insurance co’s is to reward the biggest “producers,”  while what investors need is the long term value added and problem solving you speak of. Short term, it is a big change, but long term, firms will have stickier, happier clients and a steadier revenue stream from a broader asset under management base.

A recent survey which I coordinated with fi360 and AdvisorOne.com shows tha the vast majority of brokers and investment advisors in the field want to put clients first–and if you think long term, it is in the advisor’s best interest to put their client’s best interests first at all times, as a fiduciary, than to have to look for the next sales customer.

You are absolutely right about changing the lingo as well. Think long-term client, rather than “prospect,” solving client problems and helping them meet their goals in a way that is in their best interest, and your client base will flourish. The investment advisor fiduciary model proves that this can be done. Do you know an investment advisor who is starving? No.

Banks, brokerage firms and insurance companies have to change how they offer advice, and they may have to separate advisors who really advise from salespeople who don’t have to act as fiduciaries — and those non-fiduciary salespeople ought to have a sales title, rather than one that implies an advisory, fiduciary relationship. Here is one place where the titles are very important.

Long term, changing the way these companies’ sales processes work can benefit their clients and themselves. The key is clients first, and long-term thinking.

Is all Financial Advice Alike? An Article for Investors

Is all Financial Advice Alike?

Is your advisor in the sales or the advisory business? There are very important differences that you need to know.

For many investors, finding the right advisor for finance and investments is not an easy task. How do you know how qualified and smart an advisor is? What do you need to look – and look out – for?

  1. Does your advisor put your interests first, at all times?
  2. Do you know exactly how much you pay for their advice?
  3. Does your advisor monitor your investments and let you know when changes need to be made?

If you answered yes to all of these questions, good for you! If you answered no, or are not sure, take heart – you are not alone. Read on!

Most investors are not well prepared for the investment role that they are asked to take on, whether it is deciding which which funds to select in your 401(k) fund or IRA, what to do with the money you’ve accumulated (whether to roll it over, what to invest in if you do roll it over, when – and critically, how much – to take out so that it will last as long as you live), or how much to put into a child’s college plan.

Whether an investor has great wealth to invest and a complex tax and estate plan to manage or a more modest goal, the right advisor can be an invaluable resource – and the wrong one can be the reason for higher investing costs, lost opportunities, and even failure to fulfill your financial goals.

The playing field is not level. Investments have become so complex that there is an enormous gap in knowledge between even the savviest (but non-professional) investors, and Wall Street pros. The gap between investors and investment professionals is similar to the gap between patients and doctors or clients and lawyers. You wouldn’t do surgery on yourself or defend yourself in court, would you? You entrust your medical and legal wellbeing to the doctor or lawyer. They must act in your best interest.

The same principle applies to your financial future – as an investor you entrust your money and your financial goals – your future – to financial advisors. It is reasonable to expect that the advisor(s) act in your best interest – and most investors do believe this. And there is the rub. Some advisors are required by law to act in your best interest, while others are permitted by law to act in their own, or their firm’s interest. They look alike, sound alike and many have the same title, so how can you tell the difference?

We are out to level that playing field. Knowledge is power! This blog kicks off a series of articles intended to arm investors with more of what you need to know, including how to find an advisor, on order to achieve your investing goals.

Armed with the facts, you can make better choices of advisors, clarify goals and understand some of the conflicts of interest in play on Wall Street – and that is essential if you are to achieve all you dream of.


- – – Kathleen M. McBride