In addition, Robo-Advisor assumes that clients first have defined goals and a clear understanding of their financial situation. For many, this is not the case. Answering questions such as “Is your risk tolerance low, moderate or high?” assumes that the user has a basic knowledge of investment concepts and the real impact of each of them. For robot consultants, client onboarding, facilitating the transfer of funds and securities as well as trading are carried out almost exclusively electronically through third parties and partners. Robot consultants do not hold client assets during these stages, but enter into agreements with brokerage, clearing and deposit partners who do. Robo-Advisor should ensure that it selects the appropriate ETFs and backup ETFs in order to avoid any violation of the wash sale. The SEC said permits allowing robot consultants to access customer accounts can constitute a deposit. Password access to clients` online accounts that involve the ability to withdraw assets other than qualified custodians may constitute a custodian, whether or not such access is used. In addition, consultants may be inadvertently retained if agreements between the qualified deposit bank and the advisor client allow the advisor to order the depositary to make withdrawals or transfers. To avoid this, bot consultants should determine whether and for whom such passwords or rights are available, and enter into an agreement with custodian banks that limits such advisory power, notwithstanding customer agreements to the contrary.
Given the need for social distancing and the restrictions imposed by many states to stay at home, it is likely that at some point, and perhaps for the entire period of the past few months, your company has operated in accordance with its Business Continuity Plan (“BCP”). The first way, as most robo-advisors make money, is an asset-based Wrap supplement (AUM). While traditional (human) financial advisors typically calculate 1% or more of AUM per year, most robo-advisors only calculate about 0.25% per year. They are able to charge lower fees because they use algorithms to automate trades and indexed strategies that use commission-free and inexpensive ETFs. . . .