Tuesday, December 19, 2017

End of Year Compliance Action Items

End of Year Compliance Action Items

Here are 5 compliance action items to keep in mind as 2017 comes to a close:

1. Renewal Fees

The deadline for the payment of your preliminary renewal fees was yesterday (December 18, 2017). The next deadline to be aware of is December 26, 2017, which is the deadline to submit any registration terminations in jurisdictions where you are no longer required to be registered. Please click here to view our previous Advisor Alert related to the annual renewal process and important deadlines.

2. Annual Compliance Training

If your firm hasn't done so already, now is a good time to conduct a 2017 annual compliance training. It is essential that your firm conducts an annual training for all supervised persons of the firm to establish and reinforce the firm's policies and procedures. Topics should include roles and responsibilities for the CCO and supervised persons, core compliance topics, and industry hot topics.

3. Annual Review and CCO Report

Rule 206(4)-7 of the Investment Advisers Act of 1940 and other state regulations require that Advisors implement (and maintain) a compliance program that is designed to prevent, detect and correct any violations of the securities laws. On an annual basis, the Chief Compliance Officer (“CCO”) is responsible for performing an annual review to determine the adequacy of the compliance program.

SEC Registrants: Details and findings of the annual review are required to be captured and archived in an Annual CCO Report.

4. FINRA Entitlement User Accounts Certification

At the beginning of each year FINRA requires that the Super Account Administrator ("SAA") for your firm validate the users that have access to your filing, billing and related information within 30 days of the notice. Please Note: AdvisorAssist will provide you with reminders and instructions to guide you through the process.

5. ADV Amendment

Advisors are required to file an amended Form ADV1 and Form ADV2A within 90 days of their fiscal year end. For those advisors that use December 31, 2017 as their fiscal year end (which is most of you), the deadline to file your amended ADV is March 31, 2018. Please Note:AdvisorAssist will provide you with questionnaires and reminders to guide you through the data gathering process.

As a reminder, on October 1, 2017 the United States Securities and Exchange Commission (the “SEC”) released revisions to the Form ADV 1. Advisors will need to provide additional information for Item 1 - Identifying Information, Item 5 - Information about Your Advisory Business and Item 8 - Participation or Interest in Client Transactions. For additional information on the changes, please click here to view our post on the Form ADV 1 changes.

SEC Registrants: Additional funding to your E-Bill account will be required for your annual ADV amendment. The fee is debited at the time of filing your firm's ADV and is based on the fee schedule below:

Regulatory AUM Annual SEC Amendment Fee
$100M or More $225
$25M to $100M $150
Less than $25M $40

In the meantime, should you have any questions, please contact us at support@advisorassist.com or reach out directly to your compliance consultant.

AdvisorAssist Team

Friday, November 10, 2017

Annual RIA Renewal Fees Processing and Calendar

It is that time of year when your RIA registrations fees are due on an annual basis regardless of whether an entity or an individual is registered for the entire year or a limited duration.

On Monday (11/13/2017) a notice will be sent to you from FINRA indicating that a preliminary renewal statement is now available through E-Bill on the IARD system. The statement will be based on the firm’s current registrations and calculated to assume they will remain the same in 2018. The amount shown will be the amount an RIA is required to pay by 12/18/2017. There is an opportunity to review the current registrations by 12/26/2017 in order to remove registrations no longer required for a refund on 01/02/2018 or to add additional registrations with a payment due by 01/22/2018.

Please note: AdvisorAssist will take the necessary steps to review and prepare the preliminary statement to facilitate the payment of fees. Our process is designed to complete the renewal process for each client by the end of November to get ahead of any volume related systems issues or other year-end requirements that could lead to a firm not being properly registered going into 2018.

Key dates to note include:

  • November 13, 2017: Preliminary Renewal Fee Statements available to download and review.

  • December 18, 2017: Payment due for Preliminary Renewal Fee Statement.

  • December 19, 2017: FINRA automatically transfers funds from your Flex Funding account to your Renewal account for any fees due.

  • December 26, 2017: Last Day to Submit Registration Terminations by 6 PM (ET).

  • January 02, 2018: Final Statements Available with a Balance Due or a Refund.

  • January 22, 2018: Final Renewal Fee Statement payments are due to avoid de-registration.

Consequences of Non-Payment
If applicable registration fees are not paid, firm and/or individual registrations terminate and a new application will need to be submitted. Depending on the state, a new application may begin the registration process as if it were an initial registration subject to a 30-day review period.  During the period of time where an entity or individual registration is pending, advisory services may not be offered and no fees collected.

Please contact AdvisorAssist with any questions: support@advisorassist.com and stay tuned for upcoming communications on how we can assist with your renewal process.

Wednesday, September 27, 2017

Cybersecurity: SEC Initiatives

On September 25, 2017, the U.S. Securities and Exchange Commission (“SEC”) announced the launch of the following enforcement initiatives in order to combat cyber-based threats and protect retail investors:
1.     Creation of a Cyber Unit – dedicated to:
  • Target cyber related threats and misconduct.
  • Focus on problems such as:
    • Stealing of nonpublic information.
    • Intrusions into retail brokerage accounts
    • Market manipulation schemes.
    • Threats to market infrastructure like trading platforms.
    • Dark web.
2.     Establishment of a Retail Strategy Task Force
  • Develop proactive, targeted initiatives to identify misconduct toward retail investors.  
  • Leverage data analytics, technology solutions, and the expertise of law enforcement personnel and SEC staff in order to protect retail investors.

This announcement from the SEC comes shortly after the disclosure of a 2016 breach in the SEC’s EDGAR system and a long running data breach at Equifax (one of the nation’s three major credit reporting agencies).  Click here to read our blog post on the Equifax breach.
For additional details please read the full press release: Click Here.

If you have any questions, please contact us at support@advisorassist.com or to your compliance consultant.

AdvisorAssist Team

Friday, September 15, 2017

Most Frequent Compliance Issues - Advertising Rule

On September 14, 2017 the US Securities Exchange Commission (“SEC”) released a risk alert on the most frequent compliance concerns related to Rule 206(4)-1 (“Advertising Rule”).

The SEC has identified the most common deficiencies related to compliance with the Advertising Rule:
  • Misleading Performance Results
  • Misleading One-on-One Presentations containing “Gross-only” Performance
  • Cherry Picked Profitable Stock Selections
  • Misleading Selection of Recommendations, (a.k.a. Client Testimonials)
  • Compliance Policies and Procedures related to the review and approval of Advertising

For additional details please read the full Risk Alert.

If you have any questions, please contact us at support@advisorassist.com or to your compliance consultant.

AdvisorAssist Team

Thursday, August 17, 2017

FINRA Systems - Browser Requirements

Beginning September 30, 2017, Web CRD/IARD will only support the following web browsers: 
  • Chrome versions released after 2011 (4 or higher)
  • Firefox versions released after 2011 (4 or higher)
  • Internet Explorer versions released after 2013 (11 or Edge)
  • Safari versions released after 2013 (7 or higher)
These web browser requirements will be implemented with Web CRD/IARD Release 2017.09 as they support more robust encryption and privacy protocols to ensure information is securely transmitted over the internet. You can check your current web browser at https://whatbrowser.org. If it does not meet or exceed the minimum browser requirements listed above, your firm should upgrade your web browser for all end-user computers prior to September 30 in order to maintain continued access to Web CRD/IARD.  

Wednesday, August 2, 2017

Form ADV Part 1 Update for October 1, 2017

On October 1, 2017 the United States Securities and Exchange Commission (the “SEC”) new rules for the Form ADV 1 will go into effect. Registered investment advisors (“Advisors”) submitting any new filings on or after October 1, 2017, will need to utilize the new Form ADV 1 and provide additional information as applicable. The main areas of focus that the Form ADV 1 updates impact are in Item 1 - Identifying Information and Item 5 - Information about Your Advisory Business.

Direct update:

Item 1 now requires disclosure of:

  1. all offices where the Advisor conducts business;
  2. Any outside business activities of the Chief Compliance Officer;
  3. Direct links for each social media account where the Advisor controls the content; and
  4. The Central Index Key numbers (CIK) and Central Registration Depository numbers (CRD).

Item 5 updates affect Advisors who utilize separately managed accounts (“SAM”) and offer a wrap fee program, and now requires:

  1. Breakdown of SAM assets to assets under management (“AUM”) disclosed on the Schedule D*
  2. Disclosure of SAM usage of borrowing and derivative transactions
  3. A drill down to disclosing AUM; and
  4. A breakdown of total AUM as it applies to the following clients:
    • Not residing in the United States.
    • Who participate in a wrap fee program.
    • Clients who have SAMs.
    • Identify the custodians with at least ten percent of SAM AUM.

*Based off your fiscal year end, if the AUM is $10 billion or higher the advisor is now required to file both a mid-year and end of year breakdown or if you have less than $10 billion in AUM you only have to update these figures annually.

The Form ADV 1 has added a Schedule R for umbrella registrations for private fund advisors that operate a single advisory business through multiple legal entities. While this is not required the Schedule R should simplify the process for private fund advisors. To file an umbrella registration, the advisor must be located in the United States and only advise private funds and qualified clients in separately managed accounts.

Most Advisors will not have to use the new Form ADV 1 until their renewal filing in 2018 and AdvisorAssist will be collecting this information through our renewal questionnaires. However, if an Advisor requires an “Other than Annual” filing be done after October 1, 2017, please contact your consultant and they will collect these additional items for your filing. To prepare for the implementation of these rule updates for the October 1, 2017 compliance date, AdvisorAssist recommends the best practices of:

  1. Review SAMs to ensure that the amount of assets being held, types of assets held, and the use of derivatives and borrowings in the accounts is easily reportable.
  2. Perform an annual review of custodians for SAMs to ensure you can identify the accounts and AUM with each custodian.
  3. If you operate a single advisory business through multiple legal entities, review whether an umbrella registration is best for your business.
  4. Start tracking and reviewing the additional identifying information, including CIK and CRD numbers that will be required on the Form ADV 1.
  5. Prepare and maintain comprehensive records supporting performance and rate of return calculations.
  6. Perform an annual review of the advisor’s books and records archive to ensure you are keeping the required documentation for the required duration.
For more information about the new rules, please see our blog post and the SEC summary of changes.

Evan Barrows
Brendan Furey
Conor Anderson

Friday, July 14, 2017

Colorado Division of Securities Cybersecurity Rules Become Effective Monday, July 17, 2017

Attention: State Advisors Registered in Colorado

Colorado Division of Securities has updated and streamlined rules to become effective Monday, July 17, 2017. The rules cover numerous regulatory topics including:
  • cybersecurity,
  • succession planning, and
  • equity crowdfunding.

Regarding CyberSecurity, the Division is incorporating a rule that firms must now consider. The rule outlines new requirements for investment advisers to adopt reasonable policies to protect information stored electronically, including their client’s personal information. The rule is requiring firms to conduct routine risk assessments to determine the possibility of damage to business and client accounts, and be able to identify methods for preventing and/or address any security breaches.

The full revised “Rules Under the Colorado Securities Act” can be found on the Division of Securities website, and a red-line version released earlier this year detailing the soon-to-be-enacted rules can also be accessed via the Division’s Statement of Basis and Purpose.  

For additional details on CyberSecurity read our blog post and guest post.

For additional details on Business Continuity and Succession Planning read our blog post.

If you have any questions, please contact us at support@advisorassist.com or directly to your compliance consultants.

Thank you

The AdvisorAssist Team

Tuesday, June 6, 2017

DOL Fiduciary Rule to Apply - June 9, 2017

Following numerous delays, on May 23, 2017, the Labor Secretary finally issued a statement that it would not seek another delay in the implementation of the Department of Labor’s Fiduciary Rule and its Related Prohibited Transactions Exemptions (“Fiduciary Rule”). The final rule, officially titled “Definition of the Term ‘Fiduciary’; Conflict of Interest Rule -- Retirement Investment Advice” went into effect almost a year ago on June 7, 2016, but the compliance effective date of the rule is June 9, 2017 with full compliance required by January 1, 2018. For additional details on the Fiduciary Rule read our blog post and Question and Answer discussion.

Recent History of the Fiduciary Rule

A presidential memorandum directed at the Labor Secretary back in February called for the Department of Labor (“DOL”) to examine the implications of the rule on retirement savers. On March 6, 2017, the DOL proposed a 60-day delay of the Fiduciary Rule. A few days later on March 10, 2017, a temporary enforcement policy relating to its 60-day delay proposal was released. This policy stated that the DOL would not initiate enforcement actions against advisors who did not satisfy the conditions of the rule or the exemptions during the gap period in which the rule becomes applicable but before a delay is implemented. On April 10, 2017, the DOL issued a rule extending the original applicability date from April 10, 2017 to June 9, 2017. After much debate on the legal ramifications of a further delay on the Fiduciary Rule, the DOL issued a statement that it would not seek a delay.

What is the Fiduciary Rule?

The Fiduciary Rule expands the definition of a fiduciary to anyone providing investment advice to a retirement plan or an Individual Retirement Accounts (“IRA”) for compensation (the “Advisor”). The Fiduciary Rule will apply to all retirement accounts, including rollover transactions. This is the case even if the rollover is not specifically accompanied by a recommendation by the Advisor on how to invest the assets following the rollover or if the assets will not be covered by ERISA following the recommendation. There are three ways to comply with the Fiduciary Rule while making recommendations to retirement investors:

  1. Level Fee Fiduciary (a streamlined version of the Best Interest Contract Exemption)
  2. Best Interest Contract Exemption
  3. Principal Transaction Exemption

Level Fee Fiduciary

Advisors that charge a level fee (i.e. provide services only on an “asset under management basis” or “fixed fee” basis that does not vary based on an investment recommended, not based off of commissions or trade based fees) and adheres to the following course of conduct:

  1. Acknowledgment of Fiduciary Status. The Advisor will be required to acknowledge, in writing, that it is a fiduciary. Most Advisors already acknowledge this in their Form ADV Part 2. However, since many clients have been hearing about the Fiduciary Rule in the news it is a best practice for Advisors to proactively remind clients of their fiduciary status through a tailored notice.
  2. Adhere to an impartial conduct standard. This standard does not require Advisors to find the best or lowest cost product, but the Advisor must act in the retirement investor’s best interest, charge no more than reasonable compensation (i.e. relative to factors such as the Advisor’s geographic area, size, complexity of engagement, etc.), and not make misleading statements about investment transactions, compensation, and conflicts of interest.

Best Interest Contract and Principal Transactions Exemptions

The Fiduciary Rule generally prohibits Advisors from receiving payments from third parties and from recommending certain products that increase their own compensation in connection with investment advice rendered on retirement accounts. The prohibited transactions include: (1) a prohibition against self-dealing, i.e. dealing with the assets of a retirement account in the fiduciary’s own interest or for his or her own account, (2) acting in an individual or any other capacity in any transaction involving a retirement account, or representing a party whose interests are adverse to the interests of the retirement account, and (3) receiving any compensation for one’s own account from anyone dealing with the retirement account in connection with transactions involving assets of the plan, i.e. anti-kickback provisions.

In order to address the conflicts that are inherent in these prohibited transactions, the Fiduciary Rule provides relief for compensation arrangements, such as commissions and revenue sharing, that an Advisor might receive in connection with investment advice to retail retirement investors. The Best Interest Contract Exemption requires Advisors to agree in writing with the client to its fiduciary status, adhere to basic standards of impartial conduct by giving prudent advice in the client’s best interest, avoid misleading statements, and receive only reasonable compensation. Additionally, Advisors must adopt policies and procedures reasonably designed to mitigate any harmful impact of conflicts of interest, disclose basic information about their conflicts of interest and the cost of their advice. Similarly, the Principal Transactions Exemption permits Advisors to sell or purchase certain debt securities and other investments out of their own inventories to or from plans and IRA owners if the Advisor adheres to Impartial Conduct Standards and discloses any conflicts of interest.

The Department of Labor has also issued a Field Assistance Bulletin 2017-02, A Temporary Enforcement Policy on the Fiduciary Duty Rule, which provides relief to Advisors who are working to come into compliance with the rule from enforcement actions by the Department of Labor beginning on June 9, 2017 and ending on January 1, 2018. The Department of Labor has also provided additional guidance to assist with the implementation of the Fiduciary Rule by issuing another set of FAQs. Please click here to read the FAQs. Among other things, the FAQs provide for grandfathering relief under the BICE for compensation received in connection with investment advice given prior to the applicability date of June 9, 2017. Click here to read the guidance and FAQs.

Brendan Furey
Conor Anderson

Monday, May 1, 2017

NJ Annual Written Investment Adviser Examination - 2017

Attention: State Advisors Registered in New Jersey

The New Jersey Bureau of Securities 2017 Annual Written Examination of Registered Investment Advisers is ready for your completion and submission. This year’s annual written examination must be completed online >> LINK

Your firm must complete the online examination and submit any required attachments by Thursday May 18, 2017. Failure to do so will constitute a failure to cooperate pursuant to N.J.A.C. 13:47A-14.16, and may subject you to a regulatory action, including a fine.

AdvisorAssist will be contacting you to schedule a time to assist with this regulatory requirement.

If you have any questions, please contact us at >support@advisorassist.com or directly to your compliance consultants.

Thank you
The AdvisorAssist Team

Monday, January 9, 2017

Annual FINRA Entitlement User Accounts Certification

It is that time of year again!

FINRA requires that the Super Account Administrator ("SAA") for your advisory firm log into your account to validate the users that have access to your filing, billing and related information. AdvisorAssist serves as the "Alternate Administrator" for your FINRA account. Typically, your Chief Compliance Officer ("CCO") serves as the SAA.

The AdvisorAssist team has mailed our instructions to certify and how to communicate back with us. If you have any questions, please contact us at support@advisorassist.com.

Thank you.
The AdvisorAssist Team

Below is the email you would have received from FINRA:

Subject: Annual FINRA Entitlement User Accounts Certification - [Your Firm]

Start Date: 1/9/2017
Due Date: 2/9/2017

One of the responsibilities of FINRA Super Account Administrators (SAAs) is to ensure that users in their organization who require access to applications in the FINRA Entitlement Program to perform their job responsibilities are properly entitled to these applications and the sensitive data that these applications may contain. While FINRA encourages administrators to review user accounts periodically throughout the year and to delete accounts when user terminate, FINRA conducts an annual user accounts certification program to enhance this review process. The purpose of this email is to notify you that today begins FINRA's 2017 Entitlement User Accounts Certification Period.

During this 30-day certification period, you will need to review your organization's user accounts to determine that:

  • each user has a continuing need to access FINRA application(s) on the organization's behalf;
  • each user is entitled only to the applications and privileges needed to perform current job responsibilities; and
  • only users who require access to sensitive data (e.g., Criminal History Record Information, social security or tax identification numbers, dates of birth) are entitled to access this type of data.

For your convenience, you can download your user account information into a report to send to other individuals within your organization to confirm individual's appropriate entitlement, including access to applications, privileges, and sensitive data. FINRA recommends that you certify your users on the same day you request the download to prevent having to perform a subsequent review of your users as the entitlement data may have changed since the download was requested.

If user accounts are not certified within the 30-day certification period, the capability to create, edit and clone accounts within an organization will be disabled for all Administrators and will remain disabled until an organization completes the certification process. Organizations that fail to certify their users will be referred to the appropriate regulator for follow up.

To begin the certification process, please click here. Note: At the beginning of the year while all firms are participating in the SAA certification process, user administration system response time may be a little slower than usual.

Additional entitlement information can be found on the FINRA Entitlement Program page.

For questions concerning the certification process, please contact the Gateway Call Center at:
(301) 869-6699 (Broker/Dealers)
(240) 386-4848 (Investment Advisers)
Thank you.

Sunday, January 1, 2017

Calculating Regulatory Assets Under Management (2017)

Advisors must quantify the amount of assets they manage. This year Advisors must calculate Regulatory Assets Under Management, which is slightly different from other asset calculations you are used to. Here are the key components to the calculation:

Securities Portfolio

Include the securities portfolios for which you provide continuous and regular supervisory or management services as of your fiscal year-end (typically December 31st).

An account is a securities portfolio if at least 50% of the total value of the account consists of securities. For purposes of this 50% test, you may treat cash and cash equivalents (i.e., bank deposits, certificates of deposit, bankers acceptances, and similar bank instruments) as securities.

You must include securities portfolios that are:

  1. Your family or proprietary accounts;
  2. Accounts for which you receive no compensation for your services; and
  3. Accounts of clients who are not United States persons.

For purposes of this definition, treat all of the assets of a private fund as a securities portfolio. For accounts of private funds, include in the securities portfolio any uncalled commitment pursuant to which a person is obligated to acquire an interest in, or make a capital contribution to, the private fund.

Value of Portfolio

Include the entire value of each securities portfolio for which you provide continuous and regular supervisory or management services.

If you provide continuous and regular supervisory or management services for only a portion of a securities portfolio, include as regulatory assets under management only that portion of the securities portfolio for which you provide such services.

  • Under management by another person; or
  • That consists of real estate or businesses whose operations you “manage” on behalf of a client but not as an investment.

Now that we’ve discussed the two key components, (i) Identifying the Assets; and (ii) Quantifying the Assets - Here’s the How!!

(i) Determine which assets constitute Continuous and Regular Supervisory or Management Services

You provide continuous and regular supervisory or management services with respect to an account if:

  • You have discretionary authority over and provide ongoing supervisory or management services with respect to the account; or
  • You do not have discretionary authority over the account, but you have ongoing responsibility to select or make recommendations, based upon the needs of the client, as to specific securities or other investments the account may purchase or sell and, if such recommendations are accepted by the client, you are responsible for arranging or effecting the purchase or sale.

You should consider the following factors in evaluating whether you provide continuous and regular supervisory or management services to an account.

  1. The Advisory Contract. If you agree in an advisory contract to provide ongoing management services, this suggests that you provide these services for the account. Other provisions in the contract, or your actual management practices, however, may suggest otherwise.
  2. Compensation. If you are compensated based on the average value of the client’s assets you manage over a specified period of time that suggests that you provide continuous and regular supervisory or management services for the account. If you receive compensation in a manner similar to either of the following, that suggests you do not provide continuous and regular supervisory or management services for the account:
  • You are compensated based upon the time spent with a client during a client visit; or
  • You are paid a retainer based on a percentage of assets covered by a financial plan.
  1. Management practices. The extent to which you actively manage assets or provide advice bears on whether the services you provide are continuous and regular supervisory or management services. The fact that you make infrequent trades (e.g., based on a “buy and hold” strategy) does not mean your services are not “continuous and regular.”

You should consider the following examples in evaluating whether you provide continuous and regular supervisory or management services to an account.Examples of providing continuous and regular supervision:

  1. Have discretionary authority to allocate client assets among various mutual funds;
  2. Do not have discretionary authority, but provide the same allocation services, and satisfy the criteria set forth in Instruction 5.b.(3);
  3. Allocate assets among other managers (a “manager of managers”), but only if you have discretionary authority to hire and fire managers and reallocate assets among them; or
  4. You are a broker-dealer and treat the account as a brokerage account, but only if you have discretionary authority over the account.

Examples of NOT providing continuous and regular supervision:

  1. Provide market timing recommendations (i.e., to buy or sell), but have no ongoing management responsibilities;
  2. Provide only impersonal investment advice (e.g., market newsletters);
  3. Make an initial asset allocation, without continuous and regular monitoring and reallocation; or
  4. Provide advice on an intermittent or periodic basis (such as upon client request, in response to a market event, or on a specific date (e.g., the account is reviewed and adjusted quarterly).

(ii) Determine the value of those assets identified above:

Determine your regulatory assets under management based on the current market value of the assets as determined within 90 days prior to the date of filing this Form ADV. Determine market value using the same method you used to report account values to clients or to calculate fees for investment advisory services.

In the case of a private fund, determine the current market value (or fair value) of the private fund’s assets and the contractual amount of any uncalled commitment pursuant to which a person is obligated to acquire an interest in, or make a capital contribution to, the private fund.


You should consider the following examples in calculating your value of Regulatory Assets Under Management.

The client's portfolio consists of the following:

  • $6,000,000 -- stocks and bonds
  • $1,000,000 -- cash and cash equivalents
  • $3,000,000 -- non-securities (collectibles, commodities, real estate, etc.)
  • $10,000,000 -- Total Assets

Let’s run through some Key Questions:

  1. First, is the account a securities portfolio?
  2. The account is a securities portfolio because securities as well as cash and cash equivalents (which you have chosen to include as securities) ($6,000,000 + $1,000,000 = $7,000,000) comprise at least 50% of the value of the account.
  3. Second, does the account receive continuous and regular supervisory or management services? The entire account is managed on a discretionary basis and is provided ongoing supervisory and management services, and therefore receives continuous and regular supervisory or management services.
  4. Third, what is the entire value of the account? The entire value of the account ($10,000,000) is included in the calculation of the adviser's total regulatory assets under management.

If you have any questions on these calculations, please contact us at Support@AdvisorAssist.com.