Annuity recommendations
Most retail advisors earn 6%+ commission selling certain annuities. We almost never recommend annuities. When we do, we use no-load fee-based products only — no commission flows.
ACCOUNT 0001FOLIO VIFIDUCIARY · IN WRITING
FORM ADV · PUBLIC · SEC.GOVFiduciary,
in writing.
The word gets used loosely. Below is what it concretely means at Cornerstone — six legal standards we're held to, and four practical examples of how those standards shape our behavior. Form ADV is publicly filed at SEC.gov; the standards are enforceable.
ACCOUNT 0001FOLIO VI.ITHE STANDARD · 6 LEGAL DUTIES
ENFORCED BY SEC
Six
standards.
The fiduciary standard isn't aspirational. It's six legal duties, enforced by the SEC, with a public record (Form ADV) filed annually. Violations are actionable. Below: the six, with what each actually means at Cornerstone.
- F-01
Best interest · always
Every recommendation must be in your best interest, not ours. By law. Without exception. On every decision, on every account, every meeting.
- F-02
Conflicts disclosed in writing
Any conflicts of interest are disclosed in our Form ADV. We have very few; what we have is transparent and posted at SEC.gov.
- F-03
Reasonable fees · benchmarked
Fees must be reasonable for services provided. We benchmark to industry data; the schedule is on the Fees page and on every engagement letter.
- F-04
Duty of care
We must understand your situation deeply before recommending action. Cookie-cutter advice violates the standard. Discovery takes 4 — 8 weeks for a reason.
- F-05
Duty of loyalty
Our loyalty is to you, not to any product company, custodian, or third firm. Fund choices, custodian choice, alternative-investment access — all merit-based.
- F-06
Held to it legally
Violations are actionable. The SEC enforces. Your remedy is clear. Form ADV publicly filed; complaints go on the public record.
ACCOUNT 0001FOLIO VI.IIIN PRACTICE · 4 EXAMPLES
WHAT FIDUCIARY LOOKS LIKE
In
practice.
Four behaviors that follow from the standard. Annuity recommendations, insurance products, proprietary funds, outside fees. Each is where conflicts of interest typically appear in retail finance — and where ours diverge from the broker-dealer model.
Insurance products
We don't sell life, disability, or LTC insurance. We refer to independent brokers, review existing policies for fit + adequacy, and audit the cost-benefit annually.
Proprietary funds
We don't have any proprietary funds. Funds we use are from independent companies (Vanguard, DFA, select active managers) selected on merit, not relationship.
Outside fees + soft dollars
We don't accept referral fees, soft dollars, or revenue share from any third party. The only money we receive is our direct fee from you, posted on the engagement letter.
NOTE TO FILE · Andrea Reyes · Senior Partner
The 'fiduciary' word gets diluted because firms can call themselves it without the registration that backs it up. Form ADV at SEC.gov is the actual public record. Our number is 801-XXXXX; the document runs about 60 pages and lists every conflict, every fee, every disciplinary item. We'll point you to the URL during the introduction.
ACCOUNT 0001FOLIO VI.IIIFREQUENTLY ASKED · STANDARDS
4 QUESTIONS · WE ANSWER
The
questions.
Four questions to ask any advisor. The fourth — about commissions — is the test that distinguishes fiduciary from suitability. If the answer requires qualification, you have your answer.
What's the alternative to fiduciary?
Most retail 'financial advisors' are registered representatives at broker-dealers — held to a 'suitability' standard. They must recommend things that are suitable for you, but not necessarily best for you. The difference looks small on paper and is huge in practice; suitability has been the basis for thousands of FINRA arbitrations.
How can I tell if my advisor is fiduciary?
Ask: 'Are you fiduciary on all advice, all of the time?' Many will say 'yes — when acting as an advisor' — meaning they switch out of fiduciary mode when selling products. We're fiduciary always. Period. The Form ADV makes this enforceable.
Are all RIAs fiduciary?
Yes — RIAs (Registered Investment Advisors) are fiduciary by SEC registration. 'Hybrid' advisors who hold both RIA + broker-dealer licenses can switch hats. We're an RIA only — no broker-dealer license, no insurance license, no commissions of any kind.
Why do commissions matter?
Commissions create incentive to recommend the highest-commission product, not the best one for you. We don't earn commissions — period. The fee on your engagement letter is the only money we receive.
ACCOUNT 0001FOLIO VI.IVTHE RECORD · 28 YR
PUBLIC · SEC-FILED
0ON FORM ADV
DISCIPLINARY · 28 YR
0EVER · BY DESIGN
COMMISSIONS · EARNED
100%ENGAGEMENT LETTER ONLY
FEE-ONLY
ANNUALREPORT ON FILE
OUTSIDE AUDIT
ACCOUNT 0001FOLIO VI.VINTRODUCTION · WALK THROUGH FORM ADV
