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Relay
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

Supervision queue

What the agents found, what they prepared, and every draft waiting for release. The disposition is yours.

Supervision · ran day 0, 06:25

The desks swept 7 accounts and 5 captured messages on email. 12 findings wait on a principal, 2 blocking; each arrives with the facts read, the citation and what the agent prepared.

  • Business conducted on an uncaptured channel: Record completeness
  • Performance or testimonial content in advisory-capacity material: Renner: email sent 2 days ago

An agent detects, cites and prepares. It never clears its own finding; you clear, return or block, and the disposition is recorded against the rules as they stood.

12

Open findings

2

Blocking

0

Drafts awaiting release

7 + 5

Accounts and captured messages swept, email

1 captured message not swept

msg-004 (sms, compliant-texting): the source is connected but not healthy, so what it holds since the failure is not being read. Not swept is reported as not swept, never as clear. Connected channels.

What the agents found, without being asked

What is autonomous here, and what is not
The sweep reads every account and every captured message on a healthy source, in both directions, not only the drafts an advisor submits. Detection, classification, evidence assembly, the drafted finding, the drafted remediation, the citation and the order of this queue are all autonomous. The disposition is not. Anything that fired reaches a person, so does anything whose confidence sits below its rule's floor, and so does anything a rule could not evaluate because its source is missing, which is reported rather than passed.

Business conducted on an uncaptured channel

Record completeness · Record completeness · SEC Rule 17a-4; Exchange Act Section 17(a)

Finding

calendar, voice, sms, chat, social in use with nothing capturing them. Record completeness is 0.36.

Suggested: Connect a capture source for each channel, or prohibit the channel and attest to it.

gapChannels
calendar, voice, sms, chat, social
completeness
0.36
advisorId
adv-a

Confidence 100 percent.

Prepared by the agent

  • Connect a source Connect a source for calendar, voice, sms, chat, socialConnect a capture source for each channel in use, or prohibit the channel and record the attestation.Acts: Compliance. Nothing is sent or written by accepting.
  • Task Confirm with the advisor which of calendar, voice, sms, chat, social carry client business, and route each to a captured channelOwner: Compliance. Due in 5 days.Acts: Compliance. Nothing is sent or written by accepting.

Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).

record-completeness:off-channel-gap:adv-a

Performance or testimonial content in advisory-capacity material

Renner: email sent 2 days ago · Marketing review · SEC Rule 206(4)-1, Advisers Act marketing rule

Finding

Client-facing text contains performance projection or testimonial content.

Suggested: Remove it. The firm blocks projections in client-facing drafts entirely while the FINRA projections proposal is unadopted.

containsProjection
true
containsTestimonial
false
channel
email
capacity
dual

Confidence 80 percent.

Prepared by the agent

  • Hold Hold pending dispositionHold the message. Client-facing text with a projection or a testimonial does not go out as written.Acts: Principal. Nothing is sent or written by accepting.
  • Drafted note Draft to client: A correction to my last messageIn my last message I described a return figure as if it were an outcome. It is not: it is an illustration, and the actual result will depend on markets and rates. The options themselves stand, and I would rather we discuss them on a call than in writing.Acts: Advisor sends. Nothing is sent or written by accepting.
  • Task Rewrite the message without the projection and resend through reviewOwner: Advisor. Due in 1 day.Acts: Advisor. Nothing is sent or written by accepting.

Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).

marketing-review:sec-marketing-206-4-1:msg-001

Concentration rising toward the household's ceiling

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

Finding

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%).

Suggested: Raise it with the client before the ceiling is crossed: a staged plan now is cheaper than a forced trim later. Record the conversation on the account.

d-90 31.4%d-60 33.9%d-30 36.2%d0 38%household ceiling 30%
concentrationPct
38
concentrationCeilingPct
30
concentrationDriftPts
6.6
instrument
Inherited utility holding
clientId
hh-abernathy

Confidence 100 percent.

Prepared by the agent

  • Drafted note Draft to client: Your Inherited utility holding position has grownYour Inherited utility holding holding has risen to 38 percent of your investable assets, against the 30 percent limit you set. Nothing needs to happen this week. I would like to walk through the options before it crosses the line, because a staged plan now is cheaper than a forced one later.Acts: Advisor sends. Nothing is sent or written by accepting.
  • Schedule Concentration conversation before the ceiling is crossedWithin 21 days. Relay proposes the slot; the advisor books it.Acts: Advisor. Nothing is sent or written by accepting.
  • Task Prepare a staged-reduction illustration for Inherited utility holdingOwner: Wealth strategist. Due in 10 days.Acts: Wealth strategist. Nothing is sent or written by accepting.

Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).

sales-practice:finra-2111-drift:hh-abernathy

Concentration rising toward the household's ceiling

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

Finding

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%).

Suggested: Raise it with the client before the ceiling is crossed: a staged plan now is cheaper than a forced trim later. Record the conversation on the account.

d-90 68%d-60 71.5%d-30 74.2%d0 77.1%household ceiling 80%
concentrationPct
77.1
concentrationCeilingPct
80
concentrationDriftPts
9.1
instrument
Operating business stake (illiquid)
clientId
hh-thornbury

Confidence 100 percent.

Prepared by the agent

  • Drafted note Draft to client: Your Operating business stake (illiquid) position has grownYour Operating business stake (illiquid) holding has risen to 77.1 percent of your investable assets, against the 80 percent limit you set. Nothing needs to happen this week. I would like to walk through the options before it crosses the line, because a staged plan now is cheaper than a forced one later.Acts: Advisor sends. Nothing is sent or written by accepting.
  • Schedule Concentration conversation before the ceiling is crossedWithin 21 days. Relay proposes the slot; the advisor books it.Acts: Advisor. Nothing is sent or written by accepting.
  • Task Prepare a staged-reduction illustration for Operating business stake (illiquid)Owner: Wealth strategist. Due in 10 days.Acts: Wealth strategist. Nothing is sent or written by accepting.

Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).

sales-practice:finra-2111-drift:hh-thornbury

Holdings drifted outside the stated profile

Abernathy · Sales practice · FINRA Rule 2111

Finding

Inherited utility holding is 38 percent of investable assets against a ceiling of 25.

Suggested: Document the rationale for holding, or propose a bounded reduction from the approved shelf.

concentrationPct
38
instrument
Inherited utility holding
clientId
hh-abernathy

Confidence 100 percent.

Prepared by the agent

  • Task Document the rationale for holding Inherited utility holding at 38 percent, or prepare a bounded reduction from the approved shelfOwner: Advisor. Due in 7 days.Acts: Advisor. Nothing is sent or written by accepting.
  • Schedule Concentration review with the clientWithin 14 days. Relay proposes the slot; the advisor books it.Acts: Advisor. Nothing is sent or written by accepting.

Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).

sales-practice:finra-2111-suitability:hh-abernathy

Holdings drifted outside the stated profile

Renner · Sales practice · FINRA Rule 2111

Finding

Founder single-name position is 71 percent of investable assets against a ceiling of 25.

Suggested: Document the rationale for holding, or propose a bounded reduction from the approved shelf.

concentrationPct
71
instrument
Founder single-name position
clientId
hh-renner

Confidence 100 percent.

Prepared by the agent

  • Task Document the rationale for holding Founder single-name position at 71 percent, or prepare a bounded reduction from the approved shelfOwner: Advisor. Due in 7 days.Acts: Advisor. Nothing is sent or written by accepting.
  • Schedule Concentration review with the clientWithin 14 days. Relay proposes the slot; the advisor books it.Acts: Advisor. Nothing is sent or written by accepting.

Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).

sales-practice:finra-2111-suitability:hh-renner

Holdings drifted outside the stated profile

Thornbury · Sales practice · FINRA Rule 2111

Finding

Operating business stake (illiquid) is 77.1 percent of investable assets against a ceiling of 25.

Suggested: Document the rationale for holding, or propose a bounded reduction from the approved shelf.

concentrationPct
77.1
instrument
Operating business stake (illiquid)
clientId
hh-thornbury

Confidence 100 percent.

Prepared by the agent

  • Task Document the rationale for holding Operating business stake (illiquid) at 77.1 percent, or prepare a bounded reduction from the approved shelfOwner: Advisor. Due in 7 days.Acts: Advisor. Nothing is sent or written by accepting.
  • Schedule Concentration review with the clientWithin 14 days. Relay proposes the slot; the advisor books it.Acts: Advisor. Nothing is sent or written by accepting.

Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).

sales-practice:finra-2111-suitability:hh-thornbury

Correspondence not reviewed under written supervisory procedures

Renner: email sent 2 days ago · Communications surveillance · FINRA Rule 3110(b), 3110.06 to .09

Finding

Correspondence carrying a recommendation has not been through supervisory review.

Suggested: Queue for review under the written supervisory procedures. Pre-approval is not required at this distribution.

recipientCount30d
1
containsRecommendation
true
channel
email
clientId
hh-renner

Confidence 80 percent.

Prepared by the agent

  • Task Queue this message for review under the written supervisory proceduresOwner: Team supervisor. Due in 2 days.Acts: Team supervisor. Nothing is sent or written by accepting.
  • Drafted note Draft to advisor: A recommendation went out without reviewThe message on email carried a recommendation and was not reviewed before it went out. Nothing further is needed from the client; the review is being done now, and the next one goes through the queue first.Acts: Advisor sends. Nothing is sent or written by accepting.

Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).

communications-surveillance:finra-3110-correspondence:msg-001

No retained copy behind a captured channel

Record completeness · Record completeness · SEC Rule 17a-4(b)(4), 17a-4(f)

Finding

meeting, crm captured but held by no system of record. Evidence exists and retention does not.

Suggested: Point the channel at the archive, which is the 17a-4 copy, by WORM or the audit-trail alternative.

partialChannels
meeting, crm
advisorId
adv-a

Confidence 100 percent.

Prepared by the agent

  • Connect a source Connect a source for meeting, crmPoint each of meeting, crm at the archive, so the retained copy exists and not only the evidence.Acts: Compliance. Nothing is sent or written by accepting.

Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).

record-completeness:sec-17a4-completeness:adv-a

Possible diminished capacity or financial exploitation

Okafor-Lind · Vulnerable client protection · FINRA Rules 2165 and 4512(a)(1)(F)

Finding

Specified adult aged 79 with an exploitation indicator present.

Suggested: Escalate for a hold decision under Rule 2165 and confirm a trusted contact is on file.

clientAge
79
unusualDisbursement
false
newThirdPartyContact
true
trustedContactOnFile
false
clientId
hh-okafor-lind

Confidence 70 percent.

Prepared by the agent

  • Hold Hold pending dispositionHold any disbursement or beneficiary change on this account under Rule 2165 pending a principal's decision.Acts: Principal. Nothing is sent or written by accepting.
  • Callback Callback on the number on fileCall the client on the number on file, not the number in the request, and confirm the instruction in their own words.Acts: Advisor. Nothing is sent or written by accepting.
  • Request a form Request: Trusted contact designationRequest a trusted contact if none is on file (trusted contact on file: false).Acts: Client service associate. Nothing is sent or written by accepting.
  • Task Record the conversation and the decision on the account under Rule 2165Owner: Advisor. Due in 2 days.Acts: Advisor. Nothing is sent or written by accepting.

Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).

client-protection:senior-investor-2165:hh-okafor-lind

Possible diminished capacity or financial exploitation

Abernathy · Vulnerable client protection · FINRA Rules 2165 and 4512(a)(1)(F)

Needs confirming

Nothing fired, but this rests on an inferred fact at 70 percent confidence against a floor of 80.

Suggested: Confirm or correct the inferred fact, then the verdict stands on its own.

clientAge
71
unusualDisbursement
false
newThirdPartyContact
false
trustedContactOnFile
true
clientId
hh-abernathy

Confidence 70 percent.

Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).

client-protection:senior-investor-2165:hh-abernathy

Possible diminished capacity or financial exploitation

Alcott · Vulnerable client protection · FINRA Rules 2165 and 4512(a)(1)(F)

Needs confirming

Nothing fired, but this rests on an inferred fact at 70 percent confidence against a floor of 80.

Suggested: Confirm or correct the inferred fact, then the verdict stands on its own.

clientAge
72
unusualDisbursement
false
newThirdPartyContact
false
trustedContactOnFile
true
clientId
hh-alcott

Confidence 70 percent.

Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).

client-protection:senior-investor-2165:hh-alcott

The rules behind these findings are editable on Rules and agents, and every change is in the change log.