Product · Compliance

The memo, the moment of the recommendation.

Every recommendation comes with a sourced, dated, and signed compliance memo — the regulator's homework, done before they ask for it.

Sample memo

What lands in the file the moment you click approve.

Best Interest Recommendation Memo · Calloway Household
Memo ID: BI-2026-0429-0411 · Drafted 06:14 ET · Approved 08:42 ET

Recommendation. Trim Microsoft (MSFT) position in the Calloway joint taxable account from 41.2% of household equity to a target of 28%, executed in two tranches across Q2 and Q3 2026.

Care obligation. The Calloway IPS, last reviewed 11/2024, sets a 30% single-name concentration ceiling. The current MSFT position exceeds that ceiling by 11.2 percentage points. Trimming to 28% restores compliance with a 2-point buffer. [1]

Conflict obligation. No advisor compensation is tied to the recommended action. Drift fee schedule applies; no transaction-based fees.

Disclosure obligation. Tax impact estimated at $42,800 in long-term capital gains across the two tranches. Discussed with client per the meeting note dated 03/18/2026. [2]

Rationale. Recommendation aligns with stated household objectives of capital preservation and tax efficiency in the five years approaching retirement. [3]

[1]Calloway IPS · v3 · 11/2024[2]Meeting note · 03/18/2026[3]Household plan · eMoney
What it covers

The rules a CCO would write into a checklist — automated against the work.

Reg BI
Best Interest documentation for every recommendation. Care, conflict, disclosure obligations cited inline.
Suitability
Customer profile, risk tolerance, time horizon checked against the recommended action with a written rationale.
Fee disclosure
Form CRS and ADV cross-referenced. Fee changes flagged before they ship.
Trade rationale
Why this trade, why now, why for this household. Documented at the moment of recommendation, not after.
Books & records
FINRA 4511 retention. Immutable, time-stamped, exportable. Seven-year default; longer on request.
Marketing rule
Performance claims, hypothetical returns, testimonials reviewed against the SEC marketing rule before publish.
Audit trail

Every action, with an actor and a timestamp.

Time
Actor
Action
  • 06:14:02
    Drift
    Detected concentration breach · Calloway Household · MSFT 41.2%
  • 06:14:03
    Drift
    Drafted client recommendation memo · sources [IPS, positions, prior reviews]
  • 08:42:11
    C. Ahn
    Reviewed memo · 2 edits · approved
  • 08:42:48
    Drift
    Sent memo to client portal · receipt logged
  • 08:42:49
    Drift
    Recorded in books & records · v1.0 · hash f7c2…
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