Video: Back to Basics: Filing a Form ADV That Reflects Reality | Duration: 2708s | Summary: Back to Basics: Filing a Form ADV That Reflects Reality | Chapters: Welcome and Introduction (52.54s), Compliance Focus Areas (261.19s), SEC Exam Priorities (499.97998s), AI in Wealth Management (776.115s), AI and Cybersecurity Risks (1002.365s), Annual Updating Amendment Essentials (1332.6901s), Filing and Conclusion (2346.5552s), Conclusion and Farewell (2413.34s)
Transcript for "Back to Basics: Filing a Form ADV That Reflects Reality":
Hey, everyone. Welcome to today's webinar, Back to Filing a Form ADB that Reflects Reality. My name is Allison Cooley. I am the Senior Director of Product Marketing over here at Comply, and I am joined by one of my favorite colleagues, Anne Howerlin, who is the VP of Regulatory Operations here at Comply. Hey, I said earlier today that it's Happy Annual Updating Amendment Season to all that celebrate. I love that. So we're really excited to be with you guys today. I already took care of our introductions. Just getting into a little bit of housekeeping, so anyone who's attended this session or registered for the session, you'll get a copy of this recording in the next twenty four hours from our team, so you'll be able to watch it again and we can also provide those slides as well. Then we're going to get into quickly what regulators are looking for in Form ADV, and then Anne's going to walk us through some common compliance gaps and strategic tips for preparing your AUA. And so, Anne, I would love if you can just get into before we get into this, if you don't mind just sharing a little bit about your background at Comply and what your team does just to help everyone understand. Sure. So I kind of take the approach at the beginning of my career with the lens of a regulator because I used to be one here in Texas. And I have celebrated, what is this, my eleventh AUA season So here at I've seen a lot, learned a lot with clients, and answered the same questions over and over again. And what I hope to do is just kind of provide some clarity that everyone's getting tripped up about when it comes to filing their annual updating amendment and how to best reflect their firms and regulatory filings. So, I mean, there's a regulatory filing, we do it, and we are able to craft them well with all sorts of information. AUA is our Super Bowl, it's our specialty, and we file about 3,000 of them a year. So lots of practice, and I'm looking forward to talking to everyone about the things they should look at and what to care about and what regulators are caring about, number one, and how to best navigate what the focus is these days. Because you know, it changes. That's why this industry is so exciting is that it's ever evolving and changing. You know, myself along with my brilliant team, really love supporting registered investment advisors and navigating this fun Q1 activity for all that celebrates. So, yeah, it's great. In my mind, I always think of Form ADV and all the regulatory filings and trying to explain that to someone outside the business, maybe a friend you're getting dinner with or a family member, and it's really hard to peel it back and not overwhelm people. And so, you know, one of the best things about you and your team is that you make it really simple, regardless of the size of the firm, regardless of where you're at in your compliance career. So let's just do a temperature check, right? So the SEC and FINRA released their yearly priorities, I think it's the oversight report on FINRA. And, you know, I would love for you to kind of shed some light in what you saw there and then kind of what's going on with this whole back to basics dialogue that we're getting from the regulators. Well, you know, there was a shift from Gensler to Atkins, and there was a lot of talk on how things may be looking easier to cope with when it comes to compliance. But really, it's just the focus, like we say, back to basics. And there's been a lot of talk of deregulation, you know, the SEC and state regulators are all still focused on fundamentals. And firms just need to stick to core compliance practices and making sure those disclosures are always accurate, that you're discussing conflicts, and the best ways to manage conflicts. I know here on the screen, we talk about custody. Custody is a big thing that advisors are looking to navigate. And I really find a lot of advisors have a hard time identifying that they truly have custody and which custody rules to follow, because there's different flavors that you'll have to align with whether you're state or SEC registered. And we see, you know, marketing rule violations. There are complex marketing rules that are subject to interpretation by firms, how they deploy, you know, the messaging out into the public and how to best navigate the marketing rules that are in place. So, So, cutting corners on basics is still the fastest way to draw scrutiny when it comes to the regulation and exam priorities where they sit right now. So, some things that I think are important when it comes to the ADV, right? Because we're in AUA season, we wanna think about the ADV, our operational alignment. Make disclosures are matching your day to day practices. A lot of advisors think, Oh, I haven't had any changes. I think I've looked at this form a couple of times before, pretty sure it reflects what we're doing day to day. And you'll find that if you ignore this form and only look at it maybe once a year, you need to keep an eye on it as things are changing throughout your business to identify those portions that need to be amended around this time of year. There are exams that are also increasingly focusing on gaps between what you're reflecting in these regulatory filings, what you are reflecting in the disclosure documents, and the written policies that kind of govern the compliance program. So this is a good time of year to ensure that, hey, yep, we have policies that support that what we're reflecting in the ADV is true and accurate. We can navigate any conflicts of interest that we have disclosed in our disclosure brochures and have all of those key areas addressed. And those key areas are, you know, those advisory services that are offered, cybersecurity, privacy, and regulatory safeguards that you have in place. And one thing I think is super important around this time of year as you're kind of navigating your regulatory assets under management is those fee and conflict disclosures as well. You need to be very transparent of the disclosure of fees, your conflicts of interest, your compensation structures. It's very critical because those SEC examiners look for completeness, clarity, and consistency across all of the disclosure documents and communications. So, just being very aware of the fees, because that's kind of a sensitive area that the SEC and the state examiners look to, and is a foundational piece of the exam process. I want to switch gears and talk a little bit about the SEC exam priorities because there were a couple of things called out. These come out obviously every year and it's the same old, same old with a couple of different adjustments. But when I started in this industry, one of the most surprising things that you touched on was just the reform ADV matching your policies matching your practice. And regardless of the severity of that alignment, right, you could have a marketing or not a marketing compliance team meeting every Tuesday and it's in your ADV or wherever in your policies and you don't do and you don't have evidence, the regulators are frustrated by that, right? So that's one of the most interesting things to me and I think a lot of where people get tripped up on making sure that everything is aligned there. But let's talk quickly about the SEC exam priorities, right? So, we saw some stuff on fiduciary duty and standards of context, the effectiveness of the compliance program, and then that accuracy that you were talking about earlier. Anything else you want to add on? Yeah, I mean, three core themes are it. Examiners want to see if advisors are acting in the client's best interest and managing those conflicts of interest. And we'll talk to advisors and they think, Well, I can't really think of any conflicts of interest. There's always gonna be a conflict of interest somewhere. And you have to really pay attention to your operations for the firm, how you're working with clients, how you're managing your clients and identifying those conflicts. And really transparency on fees and costs, making sure that your clients really understand the fees that they're being charged, how you're calculating them, and you adhering to best execution practices as well. So when it comes to the effectiveness of the compliance programs, I mean, we hear this over and over again, year over year, and you may think, Oh, I have no stones left unturned, and I don't have any work to do. And the truth is, it's just your effectiveness of your compliance program is going to sit with you and how much you interact with it and kind of work out that compliance muscle. Because the examiners are looking to evaluate whether your programs are reasonably designed and they're truly implemented. Because you could say it in writing, but when they get in there and have discussions with you and wanna see it in practice, that's a different story. And that seems to be kind of the difficult piece for advisors to really prove up when they're going through the examination process. And again, it's not just written policies, it's thinking about how do I show the proof of oversight? How do I show the proof of monitoring? And, you know, those moments where you take corrective action. You know, I would think if you haven't been viewed by a regulator examined in, you know, five something years, you had no corrective action at any point in time, and you were just so perfect. I would kind of take that as a thought of maybe I need to take a step back and look through things more methodically to figure out, am I really truly implementing an effective compliance program? And with that last theme, accuracy and implementation of disclosures, that's a moving target, right? Because the business is evolving and changing, the services and fees may be changing, there's different relationships coming into place. So making sure that that Form ADV and other disclosures reflect what's actually being practiced, and it'll help you in exams so you can focus on the alignment of what you're saying you're doing, and how you're going to prove that up to the regulator when you're in that process. Because you want to stop any discrepancies from being developed or shown through an exam process. And that is a common red flag with the examiners as they come and visit you and check this stuff out. So I would say, just to tie all this up, fiduciary duty, strong compliance program, accurate disclosures, I mean, they all go hand in hand. And the SEC looks at them all together to make sure that advisors are really acting in their clients' best interest. Right, so, you know, as we look into 2026, what are some new things? You know, we've got emerging technology and AI, how is that having an impact? I mean, I ask that and I'm like, how is it not having an impact, right? So, you know, I've been in lots of conversations with my role in product marketing, with our team and our regulatory services team about developing AI software and technology and solutions around this. But it's something I'd really love to hear your insights in. You know, when I see AI or advisors talking about AI, you know, it sounds really exciting, but it also gives me huge pause because I feel like there are a lot of vendors going to market with AI solutions that advisors are implementing into their tech stack that maybe haven't been thought through with a compliance or regulatory lens. And think about a notetaker, you know, it's okay, I have this AI notetaker, it's going to capture all of my conversations with my clients, it's going to make, you know, my note taking abilities really easy to contain, but regulators are kind of skeptical. What if your client says information that's, you know, non public information or something that's really personal and secure? Where's that information going? How is it being protected? And when I talk to advisory firms, when I'm out in the wild at different conferences, and a lot of them think this is a really great technology I can use, but I can't quite describe where the information goes. Or, you know, I have a hard time understanding how the technology is used and how are you using any other AI technology to provide advice? You know, finding that understanding seems to be where the question mark is right now. And if I were an advisory firm, and I'm using vendors who were deploying AI or any other AI tool, kind of take it back to looking at that tool as a regulator would and raise those questions of, you know, where's that information going? How am I using it? How can I describe this at, you know, maybe a kindergarten level to anyone and feel comfortable using it? And, you know, don't get wooed by everything that it can do because, you know, technology is great, you should use it, but you have to make sure that you understand it fully and how it affects not only your business, how you're interacting with clients, and also how regulators are gonna be interpreting it. So I would keep my eye on how regulators are you know, viewing these AI tools out when they are examining firms and seeing how, I guess what they find as we see more and more exams go on throughout the years. And there's the compliance and governance piece, AI related activities, they can be integrated into your compliance framework, which is great, and policies also should reflect how those AI tools are monitored and controlled and updated. Like, you controlling them? Do you have a way to monitor them? Do you have the ability to update anything? And make sure that you understand your supervisory oversight. The SEC wants to see active oversight on all the things, whether it's an AI tool, whether it's a XYZ vendor, because it could really impact you and the decisions that you're making for your clients. I think that was wonderful. I want to touch quickly back on that notetaker example that you shared earlier. I don't want to name many names, you and I were joking about this a little bit a few days ago where there was a venture capitalist firm that had a startup join a call and they had an AI notetaker on and, you know, the startup did their thing, the venture capitalists continued the call after that startup had left and then continued to have a normal conversation with a lot of MN PI shared a lot of information that the, you know, venture capitalist firm and those two advisors would never want to be made public. And the scandal that happened was that unbeknownst to them that AI notetaker that IT put in ended up sending the full transcript of that conversation via email to the startup. So the startup not only got to hear them, you know, say not beautiful things about them, but they got the MMPI and then it becomes this huge books and records. Was it communication? Is this? And it's kind of really turned the heat up on the conversation around AI notetakers and it's continuing on. I hear a lot of people on your team, the regulatory services team talk about it. It's just such a risky thing. But at the same time, it's like, you know, if you're working for a high, you know, if you're working in financial services, you guys aren't sitting around, you guys aren't fast, right? And so, you're not protecting yourselves and, you know, with that procurement process and with your compliance team, making sure that these tools that are built to make you more productive and be able to recap a meeting with a client easily and go back with next steps aren't also introducing that books and records scenario that I brought up. I mean, that's such a great story. I think a lot of people are probably terrified, like, oh my gosh, it sends an email of what I said, you know, and you have to be really careful, you know, when you use AI, because something like that could definitely happen to you. But, you know, you have to kind of ask yourself questions of how is this serving me? You know, when you're trying to prep for the annual updating amendment, think about does our ADV and marketing accurately describe this AI or algorithm service that we use, or do our policies reflect how AI tools are governed and supervised? Am I going to have a situation where an email was sent out to a blast of people because I don't know how to use this right? Mean, Yeah. It's an innocent mistake. It really is. And I think everyone's like, if you haven't heard of that, I mean, will reveal it. But I digress. It just could, It just could happen to anyone, honestly, just with the way conversations happen and people going in and out of calls in this world of, you know, Zoom. But I want to shift and talk a little bit about cybersecurity. Mean, we've already started to talk about this. RegSP for firms with that $1,500,000,000 and above already have complied with it, but we still have a group of folks within that $1,500,000,000 and less in RAUM. So, let's get into a little bit about what you're thinking about here. Yeah, I mean, those amended regulations, they've raised the bar for consumer data and protection and identity theft prevention, which is absolutely necessary for the times that we're in. And as you said, RegSP now requires those stronger safeguards, formalized scrutiny of the security programs, and updated breach notification. So there's a lot to think about there. And with Reg SID, it expands those red flag guidance and it covers digital FinTech accounts as well. And it's a compliance challenge, it's still deep rooted into the back to basics approach of that core compliance focus where you're keeping your policies current, monitoring vendors, you're maintaining audit ready documentation. And honestly, that's where maybe some rec tech solutions can help, automating those risk assessments, centralizing those policies, monitoring activity, and simplifying your reporting so that, you know, these updates, they aren't just rules. As a CCO, you have to identify those opportunities to, strengthen your hold on your compliance program, to support rules like these, and strengthen data protection while making compliance more efficient, and scalable, and proactive for you and your firm. And listen, there is a lot of information out there. I know we have a really great webinar on these regulation updates that I really hope everyone has an opportunity to see and subject matter experts with these roles as well. And if I were a CCO right now, I would kind of think about my key takeaways of this to implement these updates to strengthen my compliance program to be supportive of it all. We're going to switch gears now that we've covered that and, you know, should we have started this? Maybe, but we're getting into it now. Maybe. Yes. I want to get into what ADD is all about and what people are really signing off on. So we covered, you know, obviously the nuances of what goes within it but let's take a step back for any of the folks on this webinar who are filing for the first time or filing their AUA for the first time. Just give us a background of this form. Yeah, so when we're going through the annual updating amendment, it's what about my regulatory filing do I need to update? What's happened last year? You know, where does the snapshot of my firm look like as of my fiscal year end? Which for most advisors is gonna be December 31. And it's really just, you know, your form documents that you're representing to the regulators, this is where we're at up until this point. And it isn't just about updating, your assets under management, it's really a check on whether your disclosures are accurate. And when you think about your disclosures, your policies, do they really reflect how you're actually operating? Your business practices, are they aligned with risks that you take? And the examiners are looking for alignment across everything, you know with your ADV Part 1A, your Part 2A brochure, your Part 2B, your advisory agreements, of those things. It's an opportunity for you to take time to review this filing. When we talk about AUA, I just cannot go on without saying this because a lot of advisors have the hardest time calculating their regulatory AUM correctly. And when it comes to disclosing my discretionary only assets, only include those accounts where you have firms with full discretion, identify account types. You'd be surprised how many firms are at this point of year trying to decide the definitive list of what accounts that their accounts count towards, and standardize your ability to calculate that regulatory AUM, understand who your clients are, how to define your clients, avoid double counting accounts. For example, you know, household accounts or multiple accounts per client. You need to understand how to aggregate that stuff correctly. And think about as you're going through each annual updating amendment season, How can you be more efficient on calculating your assets, understanding your clients, how to categorize them, what are your assets backed under, with, and categorized as. So there's just, I've seen some firms kind of fumble over a different process doing that every year. So my advice to you would be, as you're going through this season, write down your process, think about the dates that you get information because there's a lot going on the first of the year. I wouldn't expect you to file your annual updating amendment the January, but a lot of advisors struggle getting that information from their custodians, or if they're working with third parties, how are they able to trust the information that they have? So, like you said, for the person who is either filing their annual updating amendment for the first time, or this is your eleventh time, make sure that you have a good process at this point. Don't just walk into it blindly every year and just think, oh, yeah, yeah, yeah, like, let me just double check a couple of things. It's an opportunity for you to improve your own operations and also, you know, think about that imaginary, you know, invisible string that ties across your regulatory documents with your disclosure brochures and your ADV-one filing to make sure that all that information is aligned. Because with the ADV filing, with the disclosures in the brochures, it's a regulatory decision tree of sorts. So if you're changing one thing, have to think what change is that going to build upon as well. But we sure do love our AUA filing season and I know it's absolutely necessary and required for everyone that is probably listening to this call. And it looks like one way to kick off a year. Absolutely. And I think that leads us right into, I don't know, anytime red flags are a conversation, I just love it because there's so many different traps you can accidentally fall into. And so we brought up you up here I'd love you to talk through with us. Yeah, so again, here go the fees, right? Fee disclosure inconsistencies. I've even talked to advisory firms where, you know, they've decided in the middle of the year to stop charging quarterly and maybe charge monthly or vice versa, or they're working with another third party and turns out they don't charge quarterly and they thought they did. It's really interesting when those moments happen. You know, how are you communicating this to your clients? And when you look at the fee disclosures in the brochure, when you look at the types of fees you charge in the ADV-one. I as an examiner would look, what are you reflecting to the client? What have they agreed to in the contracts? You know, all of that has to be pretty consistent. And to take it a step further, how are they calculated? You'll describe how they're calculated, let's say, in the disclosure documents and the contract, but how is that calculation going into play at the custodian? You know, you also have to have a really good handle on how your fees are calculated and how you're testing that sample pool of clients, you know, quarterly to see, okay, are we actually charging our clients appropriately? Because regulators really care about that. So that's, you know, the disclosure inconsistencies will kind of raise an eyebrow to the regulator when they're looking at your regulatory filings and what you're representing to the client, and they'll make them pick a little more on how you're deploying that in practice. And then marketing role, I just feel like a lot of people just don't get this right. I mean, can be, know, the marketing role misreporting. Failure to report the use of testimonials or performances is a big one. And it's not like it's something that regulators are very forgiving. So if you have marketing rule that you need to abide by, you need to understand it fully. And then custody related surprises, SLOAs, password access, bill pay. I mean, that's you as an advisor really kind of understanding what access do I have to the client? How can I affect my client accounts? I thought I only was just withdrawing fees from the client account at the custodian. I didn't know I had all of this other access in the form of SLOAs. Turns out I do, I guess I need to disclose that. So it's just being aware of what you have access to and how you're disclosing it and what effect you can make in client accounts. Another red flag that gets firms in trouble are failure to disclose all private funds or related persons. Again, when you think about, I feel like it's so simple. It's just back to basics, you know, like what funds are you managing? Think about the people that are related to the fund and managing the fund and any related persons that you have with your firm. You know, could be as simple as just taking inventory of that and building upon there when it comes to private funds and related persons. And then again, I had mentioned earlier the regulatory assets under management is really just not great if you make an error on calculating those. I've talked to firms before who thought they've had regulatory assets under management and it turns out it ended up being AUA. Then you have registration that could be affected. Maybe I was SEC and I was just under the wrong impression on assets under management. And now I have to go through a state registration process. I have to maybe adhere to state rules that I wasn't expecting. So it affects your basis of registration in most cases when it comes to that. But you know, again, these are all things that examiners are looking for and they often trip firms up and those are absolutely common red flags that, again, I think the fee disclosure is the big one that I see a lot of firms get tripped up with, those marketing missteps and custody surprises. So, failure disclose and calculate regulatory AUM appropriately, it's like leaving out unpaid accounts or proprietary assets or certain client types. I mean, it could really be issues for you. So catching these early can save a lot of headaches during exams. And, you know, as you go through the AUA process every year, it's good to kind of revisit these because, you know, it definitely aligns with the activity that you're going through when submitting your annual updating amendment. It's so unreturned is all I have to say in reaction to that. You know, so we're joking a little bit, but we, this is truly a strategic moment at FIRM, right? It's, it's gruesome, it's probably cumbersome, you probably wouldn't pull your hair out, so to speak, but this really is, you know, if you take a step back and think about it, it starts the year, the start to setting, you know, the tone for the compliance team. And I'd love for you to just kind of orient us around that mindset instead of, you know, another year of, you know, AUAs to get through. Right, right. Yeah, I mean, listen, the things that you update in the annual updating amendment, you know, I'll update a few items here in the ADV-one and a few items there in the ADV-2A, you really kind of need to think of it as that annual integrity test. And I love that that's kind of how we categorize it here at Comply. And it's a chance to align all of the business units. Sometimes there's one person that wears all of these hats, finance, ops, legal, compliance. And if you give it the time and respect it deserves, your undivided attention, you'd be surprised on the things that you would find. And as I kind of went on my soapbox earlier about calculating the regulatory assets under management, and understanding the client types, and understanding if you have custody and things like that. I mean, are gonna be big moments to define in your ADV filing. These are again, I love that crosswalk key data points. They are very important on how you are kind of seeding in your compliance program to support my clients, you know how I'm billing them, how I'm navigating custody if I have it, or any third parties that work with my clients, you know, what does their influence have on any of these things that we have here. And documenting your review steps. As I said at the beginning, there's so many firms that just don't document how they even go through the annual updating amendment process. It would make things easier for you if you know you're in the growth stage of your firm, and maybe you'll pass this on or delegate this to somebody else in your compliance department or some other business leader, it's really important to have that consistency. Because with consistency comes a really good principal practice to where you aren't rushing by March 31 to get this done because you have all these other Q1 obligations, the accountant wants to talk to you. I mean, there's a lot going on, right? So making sure that you document all of those steps and then consider every external validation or peer review of high risk items. Make sure that you have that extra layer of confidence before you file. Use the talent of your team, think about anyone else in the firm that has a really close handle on the operations of the firm, how you're interacting with the regulatory filings, what you're representing to clients, what's working at the custodian, really don't file this in a silo. It really takes a lot of people at the firm who are dealing with the business to help file accurately. We're coming to the end of our session. I've put together this timeline, you know, we've got three months essentially, but just to help people kind of figure out the next steps, you know, smaller firms and then all the way up through larger firms, I would love if you could give, like, you know, the small firms where I'm a compliance officer that also have a couple of other rules, those mid sized firms and enterprise sized firms, each a recommendation of the timeline and next steps for what's to come as you navigate this. You know, whether you're big or small, I think a lot of firms right now are just trying to wrap their head around, how much should we grow last year? What are our assets? Do we really have that true number of clients in those categories? Do we really have this amount of client accounts? Are our assets categorized in these percentages in these ways? We find again that you won't get this information maybe around this time in January, like the end of the month. It's kind of rare that I see a lot of advisors who have a good handle on that the first week or so of January. The ones that do, like gold star for you, I love that because we're able to get them filed pretty quickly, but totally understandable. Don't beat yourself up if you haven't even touched this yet. Just take this as a warning from me, start those AUA review processes and get your handle around where your firm stands when it comes to regulatory assets under management, your clients, how you're categorizing those assets. Because the sooner you start this, the better. You don't want to be in a position where it's the March and you're rushing, rushing, rushing due to procrastination to submit this. I mean, it's something that the regulator absolutely takes seriously. They will look and see, has this person filed their annual updating amendment in a timely manner every year? And really they care before March 31, right? But regulators don't like it when you miss that deadline. It's not something that's gonna go ahead and give you a fine immediately. But it kind of shows to the regulator in a systematic process in writing, like, I did not respect this requirement that I know is coming every year and I didn't do it. So it would make me think as a regulator, what other things do I need to pick at? Or what other parts of your compliance program maybe you aren't taking as seriously? So just take it seriously early on. This is a really good time to start. So as this timeline says, around thirty to forty five days out, just make sure everyone's aligned on regulatory assets under management, any fee disclosures or anything like that, that needs to be checked out and get that AUA filed. I would not recommend filing two weeks before the deadline. Just get it done. It's not that bad. It maybe it'll take you a couple of days, but yeah, you'll feel better. Just get it off your plate. Right. Well, you know, Anne, I have to thank you for joining this session, and I would love to get to the comments that we have on the right, but we're going to have to table them. And so anyone who's had a question or anything like that, I'm going go through them. I'll chat with Anne. We'll get back to you. But Anne, you know, it would be great, you know, I know we have a lot of clients here, but a lot of folks that are just trying to understand this, if you might just do a quick thirty, sixty second skinny on your team and the services that y'all offer for regulatory filing. Oh, yes. So, my team, we just build the institutional knowledge of all the investment advisor firms that we work with. And we process their regulatory filings with speed and execution and quality, and there's a really great dialogue between each team member and each of our clients. So if you work with us, you know someone from my team very well, because they're handling your regulatory filings definitely on an annual basis, most likely on a quarterly basis, and those off channel review times when businesses are growing and expanding, and you don't know how this affects what you are portraying to the regulators, your registrations, kind of navigating your registration obligations when it comes to individuals or even the firm, and rule changes. I mean, there's rule changes out there that affect regulatory filings all the time. So my team, they are just the smartest, most respected subject matter experts in all things regulatory filings, and they're a true partner with CCOs and registered investment advisors across the country, and they also have a lot of friendships that are really solid with state regulators as well. So we're able to phone a friend all the time to get some execution quickly for our clients, And we really enjoy what we do and building upon our knowledge and supporting our investment advisors in the best way that we can. You're right. I absolutely love how many former regulators we have. I think someone joked the other day that people retire from being regulators and come work at Comply and we're like, Love it. But, you know, it's wonderful. So, Anne, thank you so much for everyone who attended. You know, we'll get that recording out to you. If you have questions, I'll provide my email in the chat and have a great rest of your day. Thank you. Thank you.