Current Priorities

Welcome to the consolidated documentation hub for Ethical Capital Investment Collaborative. Compliance policies, client experience runbooks, investment research notes, vendor briefings, and engineering references all live here so every teammate can work from the same, reviewable source of truth.

1 Current Priorities

2 Active Priorities

URGENT: Form ADV Update In Progress 📋

Timeline: Immediate (next 7 days) Owner: Sloane Ortel (Chief Compliance Officer) Status: Legal Review Required

A comprehensive Form ADV Part 2 amendment is being prepared to address: - Entity naming standardization (DBA compliance) - Fee structure clarification (1.00% vs tiered structure) - Contact information updates (+1 347 625 9000)

Draft available at: compliance/form-adv-draft-update-2025 Legal research required: DBA compliance requirements

Critical Actions: - [ ] Resolve fee structure discrepancy (institutional vs. individual rates) - [ ] Confirm DBA registration status in Utah - [ ] Update current AUM and client count figures - [ ] Legal counsel review of entity naming requirements - [ ] File amendment with Utah Division of Securities

2.1 1. Client Waitlist Policy Implementation 📋

Timeline: Next 30 days Owner: Sloane Ortel (Chief Compliance Officer) Status: Policy Complete - Implementation Pending

Policy Complete: Comprehensive client waitlist policy created with: - AUM-based prioritization tiers ($500K+ to <$10K) - 90-day review cycles and capacity assessment framework - Community engagement program (monthly Q&A sessions) - Full regulatory compliance for fiduciary duty and fair dealing

Next Actions: - [ ] Chief Compliance Officer review and approval - [ ] Legal counsel review of DBA requirements (see compliance/dba-legal-research-handoff.md) - [ ] LACRM system configuration for waitlist management - [ ] Form ADV amendment to include waitlist disclosure - [ ] Website waitlist page development with proper disclosures

Policy Location: policies/client-waitlist-policy/

2.2 2. Utah RIA Compliance Optimization 🔥

Timeline: Next 30 days Owner: Sloane Ortel (Chief Compliance Officer) Status: Implementation Ready

Key Finding: Utah Rule R164-5-1 directly adopts SEC Rule 204-2 - our current framework is appropriate, not over-compliance.

Immediate Actions: - [x] Utah compliance framework documented - [ ] Form ADV audit (verify disclosures match actual practices) - [ ] Client file review (contracts, suitability docs, delivery records) - [ ] Billing verification (sample audit fee calculations vs. contracts) - [ ] Off-channel communications policy enforcement

Business Impact: Eliminates potential regulatory risk while optimizing compliance burden

2.3 3. Client Records Automation Integration

Timeline: Next 30 days Owner: Sloane Ortel + Hooks Developer Status: Implementation Ready

Components: - [x] Onboarding form v8 data structure documented - [x] Google Meet recording pipeline specified - [x] State registration compliance monitoring designed - [ ] API endpoints implementation (hooks developer) - [ ] LACRM pipeline integration - [ ] Testing and validation

Business Impact: Eliminates manual “firefighting email inboxes” - critical for scaling

2.4 4. Records Management Matrix Implementation

Timeline: 30-60 days Owner: Sloane Ortel (Chief Compliance Officer) Status: Framework Complete

Updated Priorities Based on Utah Research: - [x] SEC Rule 204-2 framework confirmed as Utah requirement - [ ] Complete client records completeness audit (48 clients) - [ ] Implement personal trading pre-clearance system - [ ] Annual attestations collection (Code of Ethics + communications policy) - [ ] Mock examination simulation

Compliance Impact: Full Utah Division examination readiness

3 Medium-Term Objectives

3.1 5. AUM Growth Monitoring & SEC Transition Prep

Timeline: 60-180 days (AUM dependent) Owner: Sloane Ortel Trigger Points: - $90M AUM: Begin SEC transition preparation - $100M-$110M AUM: Optimal window for proactive SEC registration - $110M AUM: Mandatory SEC registration within 90 days

Current Status: Monitor monthly AUM reporting

3.2 6. Multi-State Expansion Framework

Timeline: As client acquisition demands Owner: Sloane Ortel De Minimis Tracking: Up to 5 clients per state without registration

System Requirements: - [ ] CRM client residency tracking enhancement - [ ] Automated alerts at 4th client per state - [ ] State registration process templates

3.3 7. Examination Readiness Program

Timeline: 90 days Owner: Sloane Ortel Components: - [ ] Annual mock audit simulation - [ ] Centralized compliance file organization - [ ] Staff examination training program - [ ] Document request response procedures

3.4 8. Optimal Scaling Strategy Implementation 🚀

Timeline: 30 days immediate, 24 months strategic Owner: Sloane Ortel + Marketing Team Status: Strategic Plan Complete - Implementation Phase

Critical Actions (Next 30 Days): - [ ] California Waitlist Deployment (Week 1): Website updates, LACRM configuration, exclusive positioning - [ ] Growth State Acceleration (Week 2): NY professional network outreach, TX foundation targeting - [ ] New State Research (Week 3): WA/CO/MA/IL market analysis and regulatory prep - [ ] Performance Monitoring (Week 4): Metrics tracking, optimization planning

Strategic Milestones: - [ ] California waitlist of 10+ qualified prospects by Dec 2025 - [ ] NY +4 clients, TX +6 clients by Q1 2026 - [ ] $5.5MM+ AUM by end 2025 (conservative), $7MM+ by end 2026 - [ ] Multi-state expansion framework operational

Documents: - Optimal Scaling Path 2025-2027 - Immediate Action Checklist - Client Waitlist Policy

3.5 9. Technical Implementation Alignment 🔧

Timeline: 21 days critical path, ongoing optimization Owner: Technical Team + Business Operations Status: Roadmap Complete - Critical Path Execution

Stream 1: Data Pipeline Stabilization (Days 1-7) - [x] Backtest Universe Refresh: Baseline runs complete through size 250 with $500MM filter - [ ] Size 500 baseline completion + comprehensive scenario sweep - [ ] Factor attribution regeneration and condensed reports update - [ ] Website content sync (ethicic-site/backtest/latest/) for client-facing data - [ ] Media processing pipeline restoration (R2 migration, video processing)

Stream 2: Website Enhancement (Days 1-14) - [ ] California Waitlist Integration: Landing page, booking flow, capacity messaging - [ ] Navigation Restructure: “Research & Insights” → “Blog”, dedicated Media/Press - [ ] Visual & Performance: Hero imagery, mobile optimization, site search - [ ] Content Management: Cross-linking, trust signals, brand consistency

Stream 3: Labs System Integration (Days 7-21) - [ ] LACRM Configuration: State-based tracking, 4-client alerts, geographic dashboard - [ ] Data Lake Enhancement: Client capacity monitoring, upload/matrix optimization - [ ] Operational Automation: Agent system enhancement, workflow consolidation

Critical Dependencies: - Backtest completion → Website content updates - LACRM setup → California waitlist deployment - Mobile optimization → Client acquisition funnel integrity

Documents: - Technical Implementation Roadmap - Labs System Documentation - Data Pipeline Status

4 Backlog Items

4.1 Strategic Documentation

• Investment committee decision frameworks
• Client education module development
• Risk tolerance assessment tools
• Ethical screening simulators

4.2 Operational Optimization

• Enhanced Labs platform mobile responsiveness
• Content management system integration
• Advanced analytics for content effectiveness
• Client journey automation refinements

5 Critical Insights from Utah Research

5.1 Compliance Validation

✅ Current Approach Confirmed: SEC Rule 204-2 framework is Utah requirement, not over-compliance ✅ Hooks System Compliant: Electronic records meet SEC Rule 204-2(g) requirements ✅ Communication Archival: Gmail metadata system complies with correspondence requirements

5.2 Priority Adjustments

🔍 New Focus: Personal trading pre-clearance system (access person transactions) 🔍 Enhanced Priority: Form ADV accuracy verification (most common examination deficiency) 🔍 Added Requirement: Off-channel communications enforcement (SEC enforcement trend)

5.3 Strategic Growth Planning

📈 AUM Thresholds: Clear roadmap for state-to-federal registration transition 📈 Multi-State Expansion: De minimis framework for systematic growth 📈 Examination Readiness: Proactive approach prevents regulatory surprises

6 Weekly Review Cycle

Every Monday: - [ ] Update priority status and blockers - [ ] Assess resource allocation needs - [ ] Identify dependencies and risks - [ ] Utah compliance framework updates - [ ] AUM threshold monitoring - [ ] Multi-state client count tracking

Success Metrics: - Client onboarding cycle time reduction - Utah compliance documentation completion percentage - Examination readiness score improvement - System integration effectiveness - AUM growth trajectory monitoring

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Last Updated: 2025-09-29 Next Review: 2025-10-06 Review Frequency: Weekly (Mondays) Key Integration: Utah RIA compliance research + Optimal Scaling Strategy + Website UX Review fully integrated

7 Information Architecture

• Compliance collects the written supervisory procedures and governance artifacts that require srvo sign-off.
• Runbooks house day-to-day SOPs spanning client onboarding, reviews, and operational checklists.
• Vendors documents counterparties, escalation paths, and integration dependencies across the firm.
• Policies contains approved client-facing statements and regulatory disclosures.
• Knowledge captures data formats, glossary entries, and internal tooling documentation.
• Mirrors surfaces read-only copies of canonical docs from other repositories so they stay searchable.
• The Changelog records every notable revision, reviewer, and deployment.

8 Stewardship Guidelines

1. Keep metadata current. Update last_reviewed, review_cycle, and ownership fields as part of every change.
2. Tail Cloudflare Pages deploys and validate access policies when pushing to main.
3. Bundle pull requests with validation output (Lychee, Vale, renders) and obtain an appropriate reviewer before merging.

9 Mirrored Content

Run python scripts/sync_mirrors.py --stage to refresh external sources before committing. Each mirrored file includes a banner pointing back to its canonical location—only edit the upstream copy, then re-sync here.

Current mirrors include:

• Public site disclosures from ~/ethicic-site (privacy, terms, screening policy, etc.).
• Workbench automation docs from ~/dev/workbench/docs.
• Data format specifications that are versioned with client and regulatory deliverables.

[!important] This site remains private behind Cloudflare Access. Share links internally and avoid copying content to third-party tools.