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12 findings

Margaret Ellison, advisor (synthetic persona)Senior advisor, founder and executive practice, New YorkAbout $820M across 183 households; four relationships above $50M; 7 of those households are in this prototypeWho's who

Senior and vulnerable investors

Vulnerable client protection. The senior investor desk: exploitation indicators on specified adults, trusted contacts, holds on disbursements.

Agent read or preparedYou decide or sendClient said or holds

Vulnerable client protection · ran day 0, 06:20

I read 7 accounts for Margaret Ellison against 1 rule. I raised 3 findings, and prepared 4 actions; 4 still wait on you.

Open the findings

How I got there
  1. 1. AgentRead 7 accountsCadence: daily.
  2. 2. AgentApplied 1 rulesPossible diminished capacity or financial exploitation
  3. 3. AgentRaised what fired and what I was not sure ofA rule under its confidence floor reaches a person even when it clears.
  4. 4. YouLeft every disposition to a personI never clear my own findings.

Watch every specified adult's account for the indicators the rule names, and prepare the hold and the callback a person makes.

Reads
Every household's accounts, positions and file
Checks
Possible diminished capacity or financial exploitation
Prepares
a hold until a principal decides; a callback on a number on file; a form request; a task with an owner
Runs
Every morning
Never
Never sends, never clears its own finding, and no advisor can switch it off or loosen it without a principal.
How
1 rule, each a stated condition over facts computed from the book; under a rule's confidence floor, or without the source it needs, it asks a person rather than clears.
Built on
FINRA Rule 2165, Financial Exploitation of Specified Adults; FINRA Rule 4512, Customer Account Information

Read a written policy into it

Needs youRunningFINRA 2165FINRA 4512Daily. Last run day 0, 06:20.

Rules this desk watches (1)

Each rule is data: a stated condition over facts computed from the book, the settings a layer may tighten, what the desk prepares when it fires, and the text it is built on with where that text stands in law today.

Possible diminished capacity or financial exploitation

Flag for review

FINRA · FINRA Rules 2165 and 4512(a)(1)(F) · firm-mandatory

Fires when
the client's age is at least 65 and a disbursement is unusual or a new third party is in contact or not: a trusted contact is on file
Settings
Specified adult age: 65 (bounds 18 to 90, stricter is lower)Rule 2165 defines a specified adult as 65 or older, or 18 plus with a reasonable belief of impairment.
Prepares
a hold until a principal decides; a callback on a number on file; a form request; a task with an owner
Needs
Custodian positions and trades, Salesforce Financial Services Cloud
In law
In force since February 5, 2018, together with the trusted contact requirement in Rule 4512.
Source
FINRA Rule 2165, Financial Exploitation of Specified Adults; FINRA Rule 4512, Customer Account Information
Today
Raised 3 for Margaret Ellison.

Change this rule

Findings it raised (3)

Tune this desk for Margaret Ellison

Editing asA lower layer can only tighten; a refused change stays in the log.

AgentSenior and vulnerable investors

Vulnerable client protection · The senior investor desk: exploitation indicators on specified adults, trusted contacts, holds on disbursements.

Running

FINRA 2165FINRA 4512

Daily. 1 rule, 1 evaluable with what is connected.

Why the desks are data, and what an advisor layer may change
Each desk is one entry in the agent catalog: the human team it mirrors, the authorities it applies, the rules it watches and its cadence. Adding a desk is adding an entry. An advisor's layer can switch a desk on, run it more often or give it another rule of its scope, and every change is an entry in the same change log the rules use, replayable to any past moment. It cannot switch a desk off, slow it down or take a rule away: the same tighten-only invariant the rule set has, enforced in the resolver and shown on the desk when an attempt is refused.

Teach this desk a policy

Paste or drop a written supervisory procedure. The reader turns each sentence that carries an obligation into a candidate rule in the same shape the engine runs, cited to the sentence. You add the ones that say what the firm meant; each is in force on the next sweep and lands in the change log in your name.

What the reader does

  • Keeps only sentences with an obligation: must, may not, is required.
  • Matches the facts the engines compute, by the words a policy uses for them.
  • Reads the number and the comparator beside each fact.
  • Takes severity from the verb: a prohibition blocks, a review flags.
  • Cites the rule the sentence cites, or the paragraph.

This is the deterministic reader. In production a model reads the sentence more freely; it still only proposes, and what it proposes is still this data.