Referral fees & recommendations
Compare referral arrangements, compensation and staff recommendations with the disclosures clients actually receive.
FIN Group · Compliance Consulting
Conflicts & Disclosure Review
Have your referral fees, ownership relationships, or business incentives changed?
Review what clients are told against how your business actually operates. Our consultants compare practices with Form ADV, website and client disclosures, then document potential gaps and proposed revisions for your approval.
For RIAs, referral platforms and private fund advisers. Scoped quote · Human review · No regulatory guarantees
What we review
The scope follows your business model, registration and relationships—not a generic checklist alone.
Ownership & affiliated services
Identify ownership interests, related businesses and incentives to recommend an affiliated platform or service.
Fees & other business incentives
Review fee arrangements, revenue sharing and other economic benefits that could influence recommendations.
Form ADV & client communications
Compare applicable Form ADV brochure language, website copy, agreements and referral disclosures with current practices.
Private fund conflicts
Review disclosed allocations, co-investments, related-party services and fee or expense practices; counsel owns offering-document language.
Approvals & evidence
Document findings, proposed revisions, responsible reviewers and approval records for the firm's compliance file.
SEC enforcement context · September 28, 2026
What the Zoe Financial case highlights
In a settled administrative proceeding, the SEC found that Zoe Financial did not adequately disclose a conflict related to incentives for recommending advisers using its Zoe Wealth services. The SEC said the resulting conflict was not adequately disclosed in its Form ADV brochure until December 2024.
The distinction matters: the SEC described recommendations by salespeople beyond initial algorithm-generated matches. The matching algorithm itself did not consider whether an adviser used Zoe Wealth. Ownership-related incentives were also part of the SEC's findings.
This is a summary of the SEC's findings in a settled order, not an admission by Zoe Financial. Zoe consented without admitting the findings, except jurisdiction. The case is illustrative; it does not establish that another firm's arrangements violate the law or create a new deadline for other firms.
From facts to an approved disclosure record
1. Confirm the facts
Identify relationships, compensation, actual staff practices and relevant documents through a scoped intake.
2. Compare & prioritize
Review disclosed language against those facts and document potential gaps and proposed revisions.
3. Approve & retain
Your firm and counsel approve final language and actions; keep the findings and approval evidence in your compliance file.
- Written findings with priorities and responsible reviewers
- Disclosure comparison and proposed revisions for approval
- Implementation and recordkeeping recommendations
Fees and timing are quoted after scoping. FIN Group does not give legal advice, manage assets, raise capital or draft fund offering documents. No SEC affiliation or endorsement is implied.
Common questions
What is a conflicts and disclosure review?
A scoped comparison of a firm's actual business relationships, compensation and recommendations with what it tells clients. FIN Group identifies potential gaps, proposes revisions and documents human-reviewed findings. The firm and its counsel approve final disclosures.
When should a firm request a review?
Consider a review when referral fees, ownership, affiliated services, product recommendations or fee arrangements change, or when preparing an annual compliance review. The Zoe Financial case does not create a new filing deadline for other firms; applicable obligations depend on your facts and registration.
Is this an automated website scan?
No. A website scan cannot establish all the facts behind a conflict. This consulting engagement includes discussion of actual practices and review of relevant documents. Any AI-assisted analysis is subject to human review.
Does this guarantee compliance or replace legal advice?
No. The review is not legal advice, a certification, an SEC endorsement, an outsourced CCO appointment or a guarantee of any regulatory outcome. Counsel addresses legal interpretations; your firm remains responsible for complete and accurate disclosures and implementation.
What does the review cost?
The fee is quoted after confirming your business model, documents, relationships and review scope. No standalone package price or turnaround is advertised for this service.
Request a Conflicts & Disclosure Review
Tell us what changed and which disclosures need review. Please do not include sensitive client data in your initial inquiry.
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