Item 13. Review of Accounts


A. Review of client accounts or financial plans, along with a description of the frequency and nature of our review, and the titles of our employees who conduct the review.

We review accounts on at least a monthly basis for our clients subscribing to the following services: Wrap Account Portfolio Management, transactional Fixed Income Portfolios, Corporate Cash Program, Independent Money Managers, and Alternative Investments. The nature of these reviews is to learn whether clients’ accounts are in line with their changing life circumstances, risk parameters, investment objectives, and appropriately positioned based on market conditions, and their investment policies, if applicable. Only our Financial Advisors and/or Portfolio Managers conduct these reviews.

Financial planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request in order to recalibrate each client’s financial planning models as his or her life circumstances change.

B. Review of client accounts on other than a periodic basis, along with a description of the factors that trigger a review.

We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, a material change in the life of the client, and/or a general request by the client.

C. Description of the content and indication of the frequency of written or verbal regular reports we provide to clients regarding their accounts.

We do not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when we meet with clients.

Financial planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately contract with us for a post-financial plan meeting or request an update to their initial written financial plan.