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

Sales practice supervision

Sales practice. The branch supervisor's suitability review: concentration against the household's own ceiling, and the trend toward it.

Agent read or preparedYou decide or sendClient said or holds

Sales practice · ran day 0, 06:20

I read 7 accounts for Margaret Ellison against 2 rules. I raised 5 findings, and prepared 12 actions; 12 still wait on you.

Open the findings

How I got there

1. AgentRead 7 accountsCadence: daily.
2. AgentApplied 2 rulesHoldings drifted outside the stated profile; Concentration rising toward the household's ceiling
3. AgentRaised what fired and what I was not sure ofA rule under its confidence floor reaches a person even when it clears.
4. YouLeft every disposition to a personI never clear my own findings.

Read every account against its own stated profile, at a point and over ninety days, and prepare the conversation before the ceiling is crossed.

Reads: Every household's accounts, positions and file
Checks: Holdings drifted outside the stated profile; Concentration rising toward the household's ceiling
Prepares: a task with an owner; a meeting to schedule; a drafted note, which a person sends
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: 2 rules, 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 2111, Suitability

Read a written policy into it

Needs youRunningFINRA 2111FINRA 3110Daily. Last run day 0, 06:20.

Rules this desk watches (2)

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.

Holdings drifted outside the stated profile

Flag for review

FINRA · FINRA Rule 2111

Fires when: the share of wealth in one name (%) is more than 25
Settings: Single-name concentration ceiling: 25 (bounds 1 to 100, stricter is lower)A client IPS may set a tighter ceiling. It may not set a looser one.
Prepares: a task with an owner; a meeting to schedule
Needs: Custodian positions and trades
In law: In force since July 9, 2012; the quantitative suitability amendment took effect June 30, 2020.
Source: FINRA Rule 2111, Suitability
Today: Raised 3 for Margaret Ellison.

Change this rule

Concentration rising toward the household's ceiling

Flag for review

FINRA · FINRA Rule 2111(a), quantitative suitability, read over time rather than at a point

Fires when: the rise in one name over 90 days (points) is more than 5 and headroom under the family's one-name limit (points) is under 10
Settings: Rise over 90 days, in points: 5 (bounds 1 to 30, stricter is lower); Headroom below the household's own ceiling, in points: 10 (bounds 0 to 50, stricter is higher)Fires when the largest single name has risen by more than this over the custodian's last 90 days of valuations. Only a position this close to the household's stated limit is worth a person's time; the point-in-time rule handles a breach.
Prepares: a drafted note, which a person sends; a meeting to schedule; a task with an owner
Needs: Custodian positions and trades
In law: In force since July 9, 2012; the quantitative suitability amendment took effect June 30, 2020.
Source: FINRA Rule 2111, Suitability
Today: Raised 2 for Margaret Ellison.

Change this rule

Findings it raised (5)

AgentConcentration rising toward the household's ceilingAbernathy · Inherited utility holding has risen 6.6 points in 90 days to 38% against the household's 30% ceiling (day -90: 31.4%, day -60: 33.9%, day -30: 36.2%, day 0: 38%).Flag for review

AgentConcentration rising toward the household's ceilingThornbury · Operating business stake (illiquid) has risen 9.1 points in 90 days to 77.1% against the household's 80% ceiling (day -90: 68%, day -60: 71.5%, day -30: 74.2%, day 0: 77.1%).Flag for review

AgentHoldings drifted outside the stated profileAbernathy · Inherited utility holding is 38 percent of investable assets against a ceiling of 25.Flag for review

AgentHoldings drifted outside the stated profileRenner · Founder single-name position is 71 percent of investable assets against a ceiling of 25.Flag for review

AgentHoldings drifted outside the stated profileThornbury · Operating business stake (illiquid) is 77.1 percent of investable assets against a ceiling of 25.Flag for review

Tune this desk for Margaret Ellison

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

AgentSales practice supervision

Sales practice · The branch supervisor's suitability review: concentration against the household's own ceiling, and the trend toward it.

Running

FINRA 2111FINRA 3110

Daily. 2 rules, 2 evaluable with what is connected.

Holdings drifted outside the stated profile
Concentration rising toward the household's ceiling

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.