Can a Terminated Adviser Invoke the Broker Protocol?
This article appeared in Advisor Perspectives on May 5, 2026. To see the full article there, please visit this link. An interesting question recently came across my desk: Can an adviser who was involuntarily terminated move their clients to a new firm under the Broker Protocol? The Broker Protocol is often discussed as if it applies only when an adviser resigns, but there is a credible argument that an adviser who is involuntarily terminated can still invoke the Protocol. Wh
Isaac Mamaysky
Apr 23
Why The SEC May No Longer Allow “Hedge Clauses” In Client Advisory Agreements (And How To Replace Them Compliantly)
This article was written for and originally appeared on the Kitces Nerd's Eye View blog. It's always a pleasure to work with the Kitces team and I'm grateful for their excellent suggestions, editing, and collaboration. To see the full article on Kitces, please use this link. Executive Summary (Written by Kitces Editorial Team) Advisory firms often rely on long-standing Investment Management Agreement (IMA) templates that include liability waivers without revisiting whether th
Isaac Mamaysky
Apr 15
Solicitors, the Marketing Rule, and Registration: Navigating Paid Referral Arrangements
This is a draft working paper that is forthcoming with Kitces. Paid referral arrangements are common in the investment advisory space. RIAs often work with “solicitors” or “promoters,” who refer prospective clients in exchange for compensation. [FN 1] These include client referral firms, individual wholesalers, accountants, online adviser matching platforms, compensated bloggers, and other centers of influence that direct prospective clients to advisers. The defining feature
Isaac Mamaysky
Mar 30
Paying Advisers: Considerations Surrounding Cash Compensation
Many RIAs reach a point of growth when informal compensation arrangements no longer scale. Early on, paying advisers can be a one-off, case-by-case decision, but as a firm grows, brings on additional advisers, and professionalizes its employment agreements, compensation stops being something that can be handled informally and becomes a core part of how the firm operates. Firms need a compensation structure that is appealing to advisers, scalable so it can apply to a team (the
Isaac Mamaysky
Mar 6