Investing Personal Assets

Personal Securities Reporting and Monitoring


In order to ensure client transactions do not in any way benefit the Firm or advisor, federal regulation requires that the Firm monitor and record the personal investment holdings and transactions of all access persons.

This is far less intrusive than it sounds.

Remember, there are advisors out there who will personally buy up a depressed stock, then turn around and attempt to drive up the price by recommending all their clients buy it as well. This happens all the time. This is criminal. We must ensure it never happens under our roof.

After all, since we believe methodical indexing and intelligent rebalancing represent the most optimal path toward long-term wealth creation, it only makes sense that we eat our own cooking.

We strongly suggest each access person manage his/her personal investment accounts with the same custodian, systems, and manner in which client accounts are managed.

By personally investing on our own platform, with our own strategies, it shows we believe in what we're doing. 


Seriously, we have access to a fully digital investment platform with zero transaction fees and automatic tolerance band rebalancing with fractional shares, how could we not use it ourselves?

At the same time, this will allow the CCO the ability to easily satisfy the Personal Securities Reporting and Monitoring regulatory requirements by running confidential holding and trading reports directly within the system.

Piece of cake for all involved.

Again, these reports are internal and strictly confidential. Your holdings and transactions will not be viewed or accessed by other advisors in the firm, only you and the CCO.

As well, your personal accounts will not be subjected to any management fees.

If, for whatever reason, you feel the need to manage your personal investment accounts at an outside custodian, we're required to organize the following procedures:


Outside Holdings Reports


Every access person shall, no later than ten (10) days after the person becomes an access person and annually thereafter, file a holdings report containing the following information:

  • The title, exchange ticker symbol or CUSIP number (when available), type of security, number of shares and principal amount of each Reportable Security in which the access person has any direct or indirect beneficial ownership when the person becomes an access person;

  • The name of any broker, dealer or bank with whom the access person maintains an account in which any securities are held for the direct or indirect benefit of the access person;

  • The date that the report was submitted by the access person.

Outside Transaction Reports

Every access person shall, no later than thirty (30) days after the end of calendar quarter, file transaction reports containing the following information:

  • For each transaction involving a Reportable Security in which the access person had, or as a result of the transaction acquired, any direct or indirect beneficial interest, the access person must provide the date of the transaction, the title, exchange ticker symbol or CUSIP number (when available), type of security, the interest rate and maturity date (if applicable), number of shares and principal amount of each involved in the transaction;

  • The nature of the transaction (e.g., purchase, sale);

  • The price of the security at which the transaction was effected;

  • The name of any broker, dealer or bank with or through the transaction was effected;

  • The date that the report was submitted by the access person.

Access persons may use duplicate brokerage confirmations and account statements in lieu of submitting quarterly transaction reports, provided that the required information is contained in those confirmations and statements.

Report Confidentiality

Holdings and transaction reports will be held strictly confidential, except to the extent necessary to implement and enforce the provisions of the code or to comply with requests for information from government agencies.

Exceptions to Reporting Requirements

Access persons do not need to submit:

  • Any report with respect to securities held in accounts over which the access person had no direct or indirect influence or control;

  • A transaction report with respect to transactions effected pursuant to an automatic investment plan;

  • A transaction report if the report would duplicate information contained in broker trade confirmations or account statements that the firm holds in its records so long as it receives the confirmations or statements no later than 30 days after the end of the applicable calendar quarter.

Review of Personal Securities

Core Planning is required by the Advisers Act and applicable state law to review access persons’ initial Holdings and to do so annually thereafter. Transactions are reviewed at least quarterly.

The CCO is responsible for reviewing these transactions and holdings reports.

Access persons are subject to the reporting requirements detailed above for personal accounts and all accounts in which they have any beneficial ownership in any reportable securities. For clarification, these terms are defined in this Code.