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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

Marketing and advertising review

Marketing review. The marketing review desk: performance, projections and testimonials in advisory-capacity material, before it reaches a client.

Agent read or preparedYou decide or sendClient said or holds

Marketing review · ran day 0, 06:15

I read 5 captured messages on email for Margaret Ellison against 1 rule. I raised 1 finding, 1 blocking, and prepared 3 actions; 3 still wait on you.

Open the findings

How I got there
  1. 1. AgentRead 5 captured messages on emailCadence: daily.
  2. 2. AgentApplied 1 rulesPerformance or testimonial content in advisory-capacity material
  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.

Read every client-facing draft and captured outbound message for performance, projection or testimonial content, and hold it until it is compliant as written.

Reads
Every captured email and message, and every note before it goes to a client
Checks
Performance or testimonial content in advisory-capacity material
Prepares
a hold until a principal decides; a drafted note, which a person sends; 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
SEC Rule 206(4)-1, investment adviser marketing

Read a written policy into it

BlockingRunningSEC 206(4)-1FINRA 2210Daily. Last run day 0, 06:15.

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.

Performance or testimonial content in advisory-capacity material

Block

SEC · SEC Rule 206(4)-1, Advisers Act marketing rule · firm-mandatory

Fires when
it projects performance or it contains a testimonial
Prepares
a hold until a principal decides; a drafted note, which a person sends; a task with an owner
Needs
Nothing beyond the book
In law
In force; adopted December 2020, compliance required from November 4, 2022.
Source
SEC Rule 206(4)-1, investment adviser marketing
Today
Raised 1 for Margaret Ellison.

Change this rule

Findings it raised (1)

AgentPerformance or testimonial content in advisory-capacity materialRenner: email sent 2 days ago · Client-facing text contains performance projection or testimonial content.Block

Tune this desk for Margaret Ellison

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

AgentMarketing and advertising review

Marketing review · The marketing review desk: performance, projections and testimonials in advisory-capacity material, before it reaches a client.

Running

SEC 206(4)-1FINRA 2210

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.