Client Waitlist Policy
1 Client Waitlist Policy
Ethical Capital Investment Collaborative
Policy Effective Period: 90 days from implementation (renewable upon review) Policy Type: Temporary Capacity Management Regulatory Classification: Client Acceptance and Fair Dealing Policy
1.1 POLICY SUMMARY
Due to high demand for our investment advisory services, Ethical Capital Investment Collaborative (“ECIC,” “the firm”) is temporarily suspending its $1 account minimum and implementing a waitlist system for prospective clients. This policy establishes transparent, objective criteria for managing client capacity while maintaining our fiduciary obligations of fair dealing and loyalty.
Key Changes During Waitlist Period: - Temporary suspension of $1 minimum account requirement - Implementation of waitlist system with AUM-based prioritization - Enhanced community engagement including monthly Q&A sessions for waitlisted prospects - 90-day review cycles to assess capacity and potential resumption of $1 minimum
1.2 REGULATORY COMPLIANCE FRAMEWORK
1.2.1 Fiduciary Duty and Fair Dealing
This policy is implemented in accordance with our fiduciary duty under the Investment Advisers Act of 1940, specifically:
Duty of Loyalty: We acknowledge that prioritizing higher-AUM prospects serves our firm’s business interests. This conflict is fully disclosed to ensure informed consent from all waitlisted individuals.
Duty of Care: All waitlist communications and selection processes follow documented, objective criteria applied consistently to ensure fair treatment of prospective clients.
Fair Dealing: The waitlist system employs transparent, non-discriminatory criteria applied uniformly to all prospective clients.
1.2.2 Form ADV Disclosure Requirements
This waitlist policy will be disclosed in Form ADV Part 2A as follows:
Item 4 (Advisory Business): Description of waitlist system as temporary capacity management tool Item 7 (Types of Clients): Updated client acceptance process including objective prioritization criteria Item 11: Conflict of interest disclosure regarding firm’s preference for higher-AUM clients during capacity constraints
1.3 WAITLIST MANAGEMENT PROCEDURES
1.3.1 1. Waitlist Enrollment Process
Enrollment Channels: - Website waitlist signup form (ethicic.com/waitlist) - Direct inquiry responses - Referral program participants - Community event attendees
Required Information: - Full name and contact information - Estimated investable assets (ranges provided for privacy) - Investment timeline and objectives - Values alignment assessment - Preferred communication frequency
Enrollment Confirmation: All enrollees receive immediate confirmation email containing: - Clear explanation that waitlist placement does not guarantee client relationship - Transparent disclosure of AUM-based prioritization system - Estimated timeframe ranges (no specific promises) - Information about community engagement opportunities
1.3.2 2. Prioritization Criteria
Primary Criterion: Assets Under Management Tiers
| Priority Tier | Investable Assets | Estimated Wait Time | Selection Probability |
|---|---|---|---|
| Tier 1 | $500,000+ | 30-60 days | High |
| Tier 2 | $100,000-$499,999 | 60-90 days | Medium-High |
| Tier 3 | $25,000-$99,999 | 90-120 days | Medium |
| Tier 4 | $10,000-$24,999 | 120+ days | Lower |
| Tier 5 | Under $10,000 | TBD upon policy review | Lowest |
Secondary Criteria (tie-breakers within tiers): 1. Date of waitlist enrollment (first-come basis within AUM tier) 2. Values alignment score from intake questionnaire 3. Referral source (existing client referrals receive preference) 4. Geographic location (operational efficiency considerations)
Business Rationale for AUM Prioritization: - Higher AUM clients enable more effective implementation of our concentrated ethical strategies - Larger accounts support the operational infrastructure that benefits all clients - AUM thresholds align with the complexity and customization level of our advisory services - Revenue optimization during capacity constraints ensures firm sustainability
1.3.3 3. Community Engagement Program
Monthly Q&A Sessions: - Format: Virtual sessions via Zoom (recorded for accessibility) - Topics: Ethical investing principles, market analysis, strategy updates - Participation: Open to all waitlisted prospects - Registration: Automatic invitation to all waitlist members
Educational Content Distribution: - Monthly newsletter covering ethical investing topics - Quarterly strategy updates and performance commentary - Access to educational webinar library - Sustainable investing resource recommendations
Engagement Benefits: - Demonstrates firm expertise and investment philosophy - Maintains prospect engagement during wait period - Provides educational value regardless of eventual client status - Creates community of aligned investors
1.4 OPERATIONAL PROCEDURES
1.4.1 4. Waitlist Management System
Technology Platform: LACRM integration with custom fields for: - Waitlist enrollment date and source - AUM tier classification - Communication preferences and history - Engagement activity tracking - Selection readiness status
Record Keeping Requirements: - Complete log of all waitlisted individuals with dates and communications - Documentation of selection decisions with criteria justification - Archive of all waitlist-related communications per SEC Rule 204-2 - Quarterly waitlist status reports for compliance review
1.4.2 5. Client Selection and Onboarding Process
Selection Meetings: Monthly review of capacity and waitlist candidates Selection Documentation: Written justification for each client selected based on established criteria Form ADV Delivery: Automated delivery at least 48 hours before initial consultation Conflict Disclosure: Clear explanation of prioritization process during initial meetings
Onboarding Timeline: 1. Day 0: Waitlist selection and initial outreach 2. Day 1-2: Form ADV Part 2 delivery via email with delivery confirmation 3. Day 3: Initial consultation scheduled (minimum 48-hour Form ADV review period) 4. Day 7-14: Investment policy statement development and agreement execution 5. Day 15-30: Account opening and initial funding
1.4.3 6. Communication Protocols
Waitlist Status Updates (Quarterly): - General capacity updates without specific timeline promises - Community engagement opportunities and educational content - Policy review outcomes and any procedural changes - Transparent communication about selection criteria application
Marketing Rule Compliance: - All communications reviewed and approved by Chief Compliance Officer - No performance guarantees or unrealistic timeline promises - Fair and balanced presentation of firm capabilities and limitations - Clear disclosure of waitlist purpose and selection process
1.5 90-DAY REVIEW FRAMEWORK
1.5.1 Review Cycle Schedule
Initial Implementation: [Policy Start Date] First Review: 90 days from implementation Subsequent Reviews: Every 90 days while policy remains active
1.5.2 Review Criteria and Metrics
Capacity Assessment: - Current Assets Under Management vs. operational capacity - Client service quality metrics and satisfaction scores - Team capacity and resource utilization analysis - Technology platform scalability assessment
Waitlist Performance Metrics: - Number of individuals on waitlist by AUM tier - Average wait times by tier and actual client conversion rates - Community engagement participation rates - Prospect satisfaction with waitlist experience
Business Impact Analysis: - Revenue impact of temporary minimum suspension - Client acquisition cost analysis during waitlist period - Operational efficiency gains/losses from waitlist system - Brand reputation and market perception effects
1.5.3 Review Outcomes and Decision Framework
Policy Continuation Criteria: - AUM growth continues to exceed operational capacity - Waitlist demand remains strong across all AUM tiers - Community engagement program shows positive response - No regulatory concerns or compliance issues identified
$1 Minimum Resumption Criteria: - Operational capacity can accommodate increased client volume - Technology infrastructure can support lower-minimum accounts - Team resources adequate for expanded client base - Market conditions favorable for small account management
Policy Modification Scenarios: - Adjustment of AUM tier thresholds based on demand patterns - Enhancement of community engagement offerings - Modification of selection criteria based on operational learnings - Extension of review period if additional data needed
1.6 REGULATORY COMPLIANCE MONITORING
1.6.1 Books and Records Obligations
SEC Rule 204-2 Compliance: - All waitlist communications archived for minimum 5-year period - Complete documentation of selection decisions and criteria application - Regular backup and accessibility testing of waitlist records - Integration with firm’s overall books and records system
Form ADV Amendment Requirements: - Initial amendment to disclose waitlist policy implementation - Quarterly review of Form ADV accuracy regarding client acceptance process - Annual amendment to update waitlist outcomes and policy status - Material change amendments if policy significantly modified
1.6.2 Fiduciary Compliance Monitoring
Fair Dealing Verification: - Monthly audit of selection decisions against documented criteria - Quarterly review of communication consistency and tone - Annual assessment of overall waitlist fairness and transparency - External compliance review if significant issues identified
Conflict Management: - Clear documentation of firm’s business interest in AUM prioritization - Transparent disclosure maintained throughout prospect relationship - Regular assessment of conflict materiality and disclosure adequacy - Client feedback integration regarding disclosure effectiveness
1.7 IMPLEMENTATION CHECKLIST
1.7.1 Pre-Launch Requirements
Legal and Compliance: - [ ] Chief Compliance Officer review and approval - [ ] Legal counsel review of regulatory compliance - [ ] Form ADV Part 2A amendment preparation - [ ] Utah Division of Securities notification if required
Operational Setup: - [ ] LACRM waitlist management system configuration - [ ] Automated email templates and workflows creation - [ ] Community engagement platform setup (Zoom, newsletter system) - [ ] Staff training on waitlist procedures and compliance requirements
Marketing and Communications: - [ ] Website waitlist page development with proper disclosures - [ ] Educational content preparation for community engagement - [ ] FAQ development addressing common prospect questions - [ ] Social media and marketing material updates
1.7.2 Launch Day Activities
System Activation: - [ ] Waitlist signup form goes live on website - [ ] LACRM tracking and workflow activation - [ ] Form ADV amendment filing with regulators - [ ] Client communication regarding temporary policy change
Monitoring Setup: - [ ] Daily waitlist enrollment monitoring - [ ] Weekly communication review and compliance check - [ ] Monthly selection meeting scheduling - [ ] Quarterly review calendar scheduling
1.8 POLICY TERMINATION PROCEDURES
1.8.1 Planned Termination (90-Day Review Decision)
$1 Minimum Resumption Process: 1. 30-day advance notice to all waitlisted prospects 2. Grandfathering provisions for current waitlist members 3. Phased onboarding to manage operational transition 4. Form ADV amendment to reflect policy termination
Communication Requirements: - Clear explanation of policy change rationale - Transparent timeline for waitlist processing completion - Continued community engagement during transition period - Regular updates on onboarding progress and capacity
1.8.2 Emergency Termination Procedures
Regulatory Compliance Issues: - Immediate consultation with legal counsel - Prompt notification to Utah Division of Securities - Comprehensive remediation plan development - Enhanced compliance monitoring during transition
Operational Capacity Changes: - Rapid assessment of capacity constraints or expansions - Flexible policy modification rather than full termination - Stakeholder communication regarding operational changes - Continuous monitoring of service quality during adjustment
1.9 POLICY EFFECTIVENESS MEASURES
1.9.1 Success Metrics
Regulatory Compliance: - Zero regulatory inquiries or violations related to waitlist policy - Successful Form ADV amendment acceptance by regulators - Positive compliance audit results for waitlist procedures - Effective conflict disclosure as measured by prospect understanding
Business Performance: - Maintenance of firm’s ethical investment mission during growth phase - Sustainable AUM growth without service quality degradation - Enhanced brand reputation through transparent capacity management - Strong prospect satisfaction despite wait times
Community Building: - High participation rates in educational programming - Positive feedback from waitlisted prospects regarding firm communication - Successful conversion of waitlist participants to long-term clients - Enhanced thought leadership in ethical investing community
Policy Review Schedule: Every 90 days Next Scheduled Review: [90 days from implementation] Policy Sunset: Automatic expiration after 18 months unless renewed Emergency Review Triggers: Regulatory inquiry, operational crisis, significant market changes
Approval Required: Chief Compliance Officer, Legal Counsel Implementation Authority: Chief Executive Officer Operational Management: Client Services Team Lead
This policy demonstrates Ethical Capital Investment Collaborative’s commitment to transparent, fair, and compliant growth management while maintaining our fiduciary obligations to both current and prospective clients. The 90-day review framework ensures continuous assessment of policy effectiveness and regulatory compliance.