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Client Data Is the Compliance: Why the Client Record an Advisor Cannot Build Is the One the FinCEN Rule Assumes
Every element of the FinCEN investment adviser rule that takes effect January 1, 2028 can be built inside the firm except one. An RIA can write the program, name the officer, train the staff and schedule the test. What no internal operation produces is the substance those operations act on: a current, verified, client-specific picture of the household. That data lives in the operating accounts an adviser never sees — and there is a pathway to it.
Tight Ship
10 hours ago5 min read
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