Wealth Management Institute, Inc., (“Wealth Management Institute”) is a fiduciary to each and every client. The SEC and the State of Michigan’s Office of Financial & Insurance Regulation take the position that Investment Advisers owe their clients several specific duties as fiduciaries. According to these regulators, the fiduciary duties include:
- Advice that is suitable
- Full disclosure of material facts and potential conflicts of interest (such that the client has complete and honest disclosure in order to make an informed decision about services of the Adviser and about investment recommendations)
- Utmost and exclusive loyalty and good faith
- Best execution of transactions
- The Adviser’s reasonable care to avoid ever misleading clients
- Only acting in the best interests of clients
It is Wealth Management Institute’s policy to protect the interests of each of the Adviser’s clients and to place the clients’ interests first and foremost in each and every situation. Further, as required by securities rules and regulations, Wealth Management Institute monitors the personal trading of all access persons, defined as staff members who have access to client, trading and investment recommendations prepared by the Adviser.
CODE OF ETHICS:
Wealth Management Institute takes the issue of regulatory compliance seriously. The Adviser and its staff are required to comply with federal and applicable state securities laws. Via its written policies and procedures, Wealth Management Institute requires that all staff members (advisory representatives and associated persons) immediately report any known or suspected violations of the Adviser’s Code of ethics or securities rules and regulations to the Adviser’s President and Chief Compliance Officer, Frank Cherniawski, CFP®. Failure to report materials information will result in disciplinary actions such as a loss of authority or, depending upon severity, termination. Additionally, these persons could be subject to additional action by a regulator.
Wealth Management Institute will abide by honest and ethical business practices to include, but are not limited to:
- We will not induce trading in a client’s account that is excessive in size or frequency in view of the financial resources and character of the account;
- We will make investment decisions with reasonable grounds to believe that the decisions are suitable for the client on the basis of information furnished by the customer and we will document suitability;
- We will place discretionary orders only after obtaining clients’ authorization as evidenced by our Client Agreement and the broker/dealers’ trading authorization;
- We are never to borrow money or securities from, or lend money or securities to a client;
- We will not place an order for the purchase or sale of a security if the security is not registered, or the security or transaction is not exempt from registration in states where we provide investment advice;
- We will not place orders for clients, or recommend that the client place an order to purchase or sell a security through a broker/dealer or agent, or engage the services of a broker/dealer, agent of, advisory representative or investment advisory firm that is not licensed under states we where we provide investment advice or with the SEC;
- All Advisory Representatives will report all but exempt personal securities trading to the Chief Compliance Officer for themselves and for beneficial relationships. Exempt from reporting are: Investments in mutual funds, transactions effected as part of an automatic investment plan; securities not in the access person’s control or those the person has no influence over; certain money market fund instruments; and securities that are direct obligations of the United States. The Chief Compliance Officer is charged with approval and monitoring of personal securities transactions.
CFP® Code of Ethics
In addition to the above, we are proud to be part of the Certified Financial Planner® community. We value and adhere to the Code of Ethics and Professional Responsibility established by the Certified Financial Planner Board of Standards:
Principle 1 – Integrity: Provide professional services with integrity.
Integrity demands honesty and candor which must not be subordinated to personal gain and advantage. Certificants are placed in positions of trust by clients, and the ultimate source of that trust is the certificant’s personal integrity. Allowance can be made for innocent error and legitimate differences of opinion, but integrity cannot co-exist with deceit or subordination of one’s principles.
Principle 2 – Objectivity: Provide professional services objectively.
Objectivity requires intellectual honesty and impartiality. Regardless of the particular service rendered or the capacity in which a certificant functions, certificants should protect the integrity of their work, maintain objectivity and avoid subordination of their judgment.
Principle 3 – Competence: Maintain the knowledge and skill necessary to provide professional services competently.
Competence means attaining and maintaining an adequate level of knowledge and skill, and application of that knowledge and skill in providing services to clients. Competence also includes the wisdom to recognize the limitations of that knowledge and when consultation with other professionals is appropriate or referral to other professionals necessary. Certificants make a continuing commitment to learning and professional improvement.
Principle 4 – Fairness: Be fair and reasonable in all professional relationships. Disclose conflicts of interest.
Fairness requires impartiality, intellectual honesty and disclosure of material conflicts of interest. It involves a subordination of one’s own feelings, prejudices and desires so as to achieve a proper balance of conflicting interests. Fairness is treating others in the same fashion that you would want to be treated.
Principle 5 – Confidentiality: Protect the confidentiality of all client information.
Confidentiality means ensuring that information is accessible only to those authorized to have access. A relationship of trust and confidence with the client can only be built upon the understanding that the client’s information will remain confidential.
Principle 6 – Professionalism: Act in a manner that demonstrates exemplary professional conduct.
Professionalism requires behaving with dignity and courtesy to clients, fellow professionals, and others in business-related activities. Certificants cooperate with fellow certificants to enhance and maintain the profession’s public image and improve the quality of services.
Principle 7 – Diligence: Provide professional services diligently.
Diligence is the provision of services in a reasonably prompt and thorough manner, including the proper planning for, and supervision of, the rendering of professional services.