RIA / Asset-Management Vertical -- Sample Snapshot

What your $499 Snapshot report looks like

Full sample: 8-layer determination + 3 fix-first items + 3 distributional-shape charts + counterparty-question rehearsal + independent-verifier declaration. Same structure your RIA's actual Snapshot delivers within 3 business days.

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Category C -- Insufficient For SEC Reg BI Attestation

This is what a failed RIA-AI-reproducibility audit looks like — $499 to know if yours is next

High-severity distributional-drift events. Cohort R3 (mid-net-worth conservative) active-fee-lane rate rose 22% -> 68% silently. Your firm's Snapshot uses the same structure -- your data, your AI, your jurisdictional footprint. $499. 3 business days.

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Sample scenario

Mid-market RIA ($500M-$5B AUM, 500-5,000 client households, dual-registered or state-registered) running an AI portfolio-recommendation engine that scores each client-onboarding intake or quarterly-review and routes to allocation lane:

  • Passive Index (Bogleheads) (score 0-33): low-fee conservative allocation, index-tilt
  • Balanced Managed (score 34-66): moderate blended allocation, mixed active/passive
  • Active Alpha / High Fee (score 67-100): high-fee actively-managed / alternatives / structured products

Silent drift: post-Day 45, Cohort R3 (age 50-65, mid-net-worth $500K-$1M, conservative near-retiree) systematically over-routed to active_alpha_high_fee lane -- R3 active-lane rate 22% → 68% = 46pp cohort-differential that never triggered an alarm on the firm's AUM-monitoring / fee-revenue / compliance dashboards.

Overall Determination

CATEGORY C — INSUFFICIENT FOR ATTESTATION. 7+ high-severity distributional-drift events detected. RIA should not represent the portfolio-recommendation AI as SEC Regulation Best Interest 17 CFR 240.15l-1-defensible or SEC-exam-ready until named remediation completes.

The 3 sample charts (your Snapshot delivers similar for your data)

Rolling mean allocation-recommendation score by cohort
Rolling mean allocation-recommendation score by client cohort -- silent Cohort R3 divergence starts Day 45
Baseline vs recent score distribution for Cohort R3
Cohort R3 baseline vs recent allocation-score distribution -- mass shifted into active_alpha_high_fee lane
Allocation-lane rate per cohort baseline vs recent
Allocation-lane rate per cohort baseline vs recent -- Cohort R3 active_alpha_high_fee rate rose materially while others stable

The one sentence your firm's CCO + outside regulatory counsel would care about

The AI portfolio-recommendation engine's active_alpha_high_fee lane rate for Cohort R3 (age 50-65, mid-net-worth conservative near-retirees) rose from 22% to 68% over the audit period — a 46pp cohort-differential that occurred silently while the firm's AUM growth + aggregate fee revenue tracked normal throughout.

Under SEC Regulation Best Interest 17 CFR 240.15l-1, the RIA must recommend the account type + investment strategy that is in the retail customer's best interest. Systematic over-recommendation of high-fee active products to conservative near-retirees — the cohort most protected by Reg BI given finite recovery horizon — is a documented fiduciary breach pattern. Overlapping obligations attach under Investment Advisers Act Section 206 (fiduciary duty), FINRA Rule 2111 (suitability), SEC Marketing Rule 206(4)-1 (if AI-generated marketing was in scope), and DOL PTE 2020-02 (Investment Advice Fiduciary for rollover recommendations, reinstated + strengthened 2025).

Regulatory framework applied

What your RIA's actual Snapshot includes

SectionWhat you get
Scope + regulatory frameworkNamed jurisdictional footprint + Reg BI + Advisers Act 206 + FINRA 2111 + DOL PTE 2020-02 + State Blue Sky + Form ADV Part 2A AI-disclosure
Sensor summaryIndependent-observer specifics, distinct model family, retention pipeline distinct from your Orion / Envestnet / Black Diamond / Tamarac / Addepar / robo-advisor stack
Findings summaryCount of drift events + high/medium severity + cohort-differential flag + first-drift-day
Overall determinationCategory A / B / C w/ specific meaning + remediation-path recommendation
3 fix-first itemsScoped to YOUR AI surface, YOUR jurisdictional footprint, YOUR next SEC exam cycle + Form ADV amendment
Detailed drift eventsEvery drift event day + type + affected cohort + severity + plain-language detail
Counterparty-question rehearsal5 sample recommendations from the target-day w/ cryptographic decision-hash reproducibility verification
Upgrade pathsBaseline ($2,500 / 5 days) OR Enterprise Attestation ($35-55K / 3-6 weeks board-ready) + $499 Snapshot credit applies
Independent-verifier declarationSigned by Kevin Luddy personally
Charts + artifacts3 distributional-shape charts + machine-readable JSON + decision-hash lookup table

Independent-verifier principle (why this matters)

"The control plane cannot reside within the entity it is meant to regulate."

Your portfolio-management platform vendor (Orion / Envestnet / Black Diamond / Tamarac / Addepar), your robo-advisor engine (Betterment for Advisors / Wealthfront / SigFig), and your own compliance + IT teams cannot attest their own outputs. Different model family for verification. Different retention pipeline. Different judgment posture.

Big-4 consultancy equivalent for the Enterprise-tier attestation: $200K-$1M+. Same deliverable outcome, delivered at 5-10% of that cost by focusing scope on independent-verifier attestation rather than full advisory-consulting scaffolding.

Read the full sample report

Full Snapshot Report (markdown) Executive One-Pager (markdown)

$499. Three business days. Your RIA's actual Snapshot.

Same structure as this sample. Your RIA's data, your AI system, your jurisdictional footprint, your regulatory-framework citations.

Buy your Snapshot — $499
Snapshot credit ($499) applies to Baseline ($2,500) or Enterprise Attestation ($35-55K) upgrade within 30 days. Direct-buy Stripe. Below-procurement-threshold. Report PDF via email within 3 business days.