Under classic Modern Portfolio Theory, there is a single portfolio that is considered to have the most efficient risk/return balance for a given target return or target risk level; any portfolio which deviates from the “optimal” allocation must, by definition, either offer lower returns for a comparable level of risk, or result in higher risk for the same level of return. Accordingly, as the theory is extended, advisors should avoid making portfolio shifts that constitute tactical “bets” in particular stocks, sectors, asset classes, etc., as it must by definition result in a portfolio that is not on the efficient frontier; one that will be accepting a lower return for a given level of risk, or higher risk for a comparable return. Unfortunately, though, this perspective on MPT with respect to making tactical portfolio shifts is not accurate, for one simple reason: it is based on an invalid assumption that there is a single answer for the “right” return, volatility, and correlation assumptions that will never change over time, even though Markowitz himself didn’t think that was a good way to apply his theory!

As advisory firms seek to refine their fee structures and find ways to add value for (and generate new revenue from) their existing clients, one of the more interesting shifts in the industry over the past couple years has been away from billing on assets under management and towards assets under advisement, which are those outside held-away assets (e.g., a 401(k) plan at a current employer) on which an advisor may make recommendations, but not necessarily effect any transactions (because it’s not under their direct management). The appeal of such an approach is understandable: qualified plans are an ever-increasing piece of clients’ nest egg, especially for those in their 30s, 40s, and 50s, and the dilemma advisors often face is that, while a potential client might have significant net worth, much of that is tied up in accounts that the advisor can’t manage directly.
In this week’s #OfficeHours with @MichaelKitces, my Tuesday 1PM EST broadcast via Periscope, we discuss the ways in which advisors are working with clients with substantial held-away assets, the issues they may face when charging an assets-under-advisement (AUA) fee on outside assets, and some operational challenges that advisors need to think about before adding on this type of fee structure.
The quintessential example of a client where an AUA fee may be a better fit than an AUM fee is the still-working client with a moderate (e.g., $150,000) brokerage account, and a sizable (e.g., $350,000) 401(k) plan at a current employer, where the client can afford to pay the advisor a reasonable fee in the aggregate, but not necessarily “just” from the account that’s available to manage.
There are a few ways to handle situations like this. In some cases, the advisor simples takes the client on in hopes of getting that sizable roll-over down the road (even if it’s an unprofitable client for years up until that point). Others may set a minimum annual fee for clients if their available assets fall under a certain threshold, ensuring that there is a sufficient level of revenue per client to service the client, and letting those with sufficient net worth (even if not all available to manage) to decide for themselves whether to move assets, or just pay the fee.
The third approach that’s emerging, though, is simply to not charge only on the assets that the advisor manages directly, but also setting an assets under advisement fee for those outside held-away assets that might provide advice on, even if the advisor doesn’t (or can’t) have discretionary authority. For which the AUA fee is typically lower, recognizing that while the advisor does provide some services, it is less than the full-service management (for the full-service management fee) on the actual managed accounts.
However, charging an AUA fee it’s not without its potential pitfalls. In some cases, clients may not want to pay for “just” asset allocation advice they have to implement themselves. And if an advisor gets the client’s login credentials to do it for them, the service is a lot less cost efficient due to the added layers on manual work involved, and means that the advisor has custody of those assets (and as such, is subject to an annual surprise custody audit under the SEC custody rule). Moreover, if the client gets accustomed to paying a lower fee to have the outside 401(k) “advised upon”, they may not want to roll over and pay a full management fee when the time comes (if the advisor has not effectively distinguished the value). Which can be especially challenging for advisors with a more passive approach, since at least active managers can claim there is additional value in rolling over by being able to implement full investment management process (e.g., offering “tactical management of retirement assets to minimize sequence of returns risk”).
Beyond those challenges, advisors also need to figure out how they’re actually going to bill on those held-away assets. As since advisors generally can’t deduct fees directly from a 401(k) account, they will either have to bill from managed accounts they do oversee (which is bad news for the advisor’s performance numbers, since the fees for the entire pie and coming from just the advisor’s slice), or send the client an invoice and implement technology to bill them directly.
These challenges to adopting an AUA fee aren’t insurmountable, however, but do require some careful thought and planning in advance. As ultimately, charging a fee on assets under advisement may be a good way for certain advisors to expand their relationship with existing clients, especially those who are still in their working years and have a sizable 401(k) plan that is unavailable to be managed directly. However, the AUA fee has got to make sense from a business perspective as well, which means having a clear operational game plan for calculating fees, dealing with all the extra manual work, and for navigating the regulatory minefield.

In today’s increasingly competitive landscape for advisory firms, financial advisors are looking for any way they can to differentiate. Whether it’s their experience and credentials, specialization or depth of services, or simply the sheer size of the firm, based on its assets under management. After all, the reality is that – justified or not – a sizable reported AUM does imply a certain level of credibility and represents a form of social proof (the firm “must” be good, or it wouldn’t have gotten so much AUM, right!?).
As a result of this trend, though, advisory firms are increasingly pushing the line in counting – or potentially, over-counting – their stated assets under management. Which is important, because not only is overstating AUM a potential form of fraudulent advertising, but the SEC has very explicit rules to determine what should be counted as AUM (or not) for regulatory purposes.
Specifically, the SEC states in its directions for Form ADV Part 1 that regulatory AUM should only include securities portfolios for which the advisor provides continuous and regular supervisory or management services. And while most financial advisors today are regularly working with clients regarding their investment securities, not all advisors are necessarily providing “continuous and regular” services on their client accounts. In fact, if the advisor doesn’t have direct authority to implement client trades (either with discretion or after the client accepts the advisor’s recommendation), it’s virtually impossible to include the account as part of regulatory AUM.
The greater challenge, though, is that the increasingly common offering of comprehensive financial planning services – where advisors provide holistic financial planning advice on all of a client’s net worth – does not mean the advisor can claim all of those assets as regulatory AUM. In fact, most of the time the advisor should not include outside 401(k) plans and other non-managed assets that were advised upon as part of the financial plan, nor the value of brokerage accounts holding mutual funds and various types of annuities (unless the advisor truly provide ongoing management services), nor TAMP or SMA assets (unless the advisor retains the discretionary right to hire/fire the manager and reallocate to another one). In fact, even having discretion over an account doesn’t automatically ensure it being counted as regulatory AUM, particularly if it’s a passive buy-and-hold account, unless the advisor can actually substantiate that monitoring and due diligence is occurring outside of any ad-hoc or periodic client review meetings!
Fortunately, for advisors who want to report some number representing the total scope of their advice – including the amount of assets that don’t count as regulatory AUM – it is permissible to report on Assets Under Advisement (AUA) in the advisor’s marketing and in Part 2 of Form ADV, as long as the advisor can document and substantiate the calculation process. But the fact that it’s permissible to report both AUM and also a (typically large) AUA amount doesn’t change the fact that, when reporting regulatory AUM itself, it’s crucial to report the right number!

The ongoing decline in interest rates since the financial crisis have been a boon for those looking to refinance a mortgage or businesses looking to borrow, but an immense challenge for investors that rely on fixed income returns, from insurance companies to individual accumulators and retirees. And as bond returns grind lower, it has brought a renewed focus on costs (that eat up an ever-larger percentage of a smaller return), including the question of whether financial advisors should charge less for managing a bond portfolio compared to a stock portfolio.
In this week’s #OfficeHours with @MichaelKitces, my Tuesday 1PM EST broadcast via Periscope, we look at the question of whether advisors really should be charging separate and different fees on the fixed income versus equity allocations in a portfolio, including and especially for those who also deliver extensive financial planning services as a part of their AUM fee as well.
Of course, given that the typical bond mutual fund is already less expensive than the average stock mutual fund, arguably the asset management industry has already spoken and suggested that the fees should not be the same. If only because today’s low bond yields, plus the more limited volatility of bonds (at least compared to stocks), means there’s just only so much opportunity to create active management value in bonds and outearn that fee in the first place.
On the other hand, the reality is that most advisors don’t manage just all-bond or all-stock portfolios as a mutual fund does. Advisors typically manage blended portfolios of stocks and bonds, sometimes tactically managing amongst all those asset classes, and an increasingly large portion of the AUM fee is being allocated to financial planning services anyway… which are based on the amount of actual financial planning work to be done, and arguably remain the same regardless of how the portfolio happens to be invested.
And in fact, with the looming Department of Labor fiduciary rule taking effect in April of 2017, charging different fees for stock versus bond allocations may become a prohibited transaction anyway, at least in an IRA where the advisor has discretion over the portfolio’s overall allocation in the first place. Which means that while advisors might charge less for conservative model portfolios compared to those that are more aggressive (and in theory have more active management opportunities), or begin to unbundle their planning and investment management fees altogether, but the question of whether to charge differently for bonds and stocks within the same portfolio may soon be a moot point anyway!
While much of the growth in P2P lending (over $5B in loan volume in 2014 alone!) has been driven by borrowers looking for appealing alternatives to traditional banks and financial institutions like credit card companies, the growth has only been possible because of the matching investor demand. After all, from the investor’s perspective, P2P loan investing is little more than an opportunity to lend money to other individuals and earn an interest rate yield, not unlike any other “bond” investment. Except in a world where Treasury Bonds and intermediate Corporate bonds or CDs may yield little more than 1% to 2%, the P2P loan has a starting yield of 5.3% for “high-quality” notes and an average rate of over 13%!
Of course, the significant caveat with Peer-to-Peer investing is that some loans will default, even over their relatively limited three to five year terms, and thus the final net returns will be substantively lower than the top-line interest rate suggests. After all, P2P loans are unsecured personal loans, often to people who have credit issues in the first place (and thus why they seek out loans with interest rates of 5.3% to almost 30%!).
Nonetheless, the rise of P2P platforms makes it feasible for investors to extensively diversify across hundreds of Peer-to-Peer lending notes by investing into fractional loan shares, managed by technology that facilitates the process of routing a borrower’s loan payments out to what might be dozens or hundreds of investors who each contributed incrementally to the loan.
In fact, the growth of the P2P marketplace, along with the introduction of institutions, is beginning to create the potential for advisors and their clients to access P2P loans, as a unique form of ‘alternative’ fixed income asset class with appealing yields. On the other hand, the growth of institutional buyers may also be pushing available investor yields down, making it harder for individual investors to compete… which is even more troubling given that P2P loans have enjoyed record net returns on the back of an economic expansion, but face the prospective risk that forward returns could be far lower if/when the next recession arrives!
The traditional approach to portfolio design involves diversifying the portfolio with low-correlation investments to help maximize the portfolio’s return for a given level of risk (or alternatively to minimize risk for a given level of return).
Yet from the holistic financial planning perspective, the reality is that the portfolio – or more generally, an investor’s “financial capital” – is only one asset on the household/personal balance sheet. And for accumulators who are still working, it’s not even the biggest asset, often trumped by the individual’s human capital that may be 2X, 5X, or 10X the value of his/her financial capital!
The significance of this distinction is that to truly maximize the risk/return characteristics of an individual’s total balance sheet, and all types of capital, it’s crucial to not just view the portfolio on a standalone basis, but to invest the portfolio to diversify around the often-much-larger human capital instead. Which means workers in conservative “bond-like” jobs might have even more equity-heavy portfolios, while those in more aggressive “stock-like” jobs should invest even more conservatively!
And even for those who are otherwise comfortable with their overall level of risk and equity exposure, arguably the future of designing portfolios for accumulators in particular – where human capital is really the dominant asset – is that the asset class and sector exposures of the portfolio should be adjusted around the risk/return characteristics of the worker’s job. For instance, those who work in the tech industry might really want to own less of the Technology sector in their portfolio! And ironically, the approach is especially relevant for financial advisors themselves, who are inherently so exposed to the economic and stock market cycle by virtue of their job, that they should own less in stocks themselves… or at least, far less in Financials!
As a guaranteed income stream that cannot otherwise be liquidated or reinvested, most retirees don’t think of their Social Security benefits as an asset. Nonetheless, its value actually can be calculated, given known payments and reasonable assumptions regarding interest/growth rates and life expectancy.
And in fact, the payments are significant enough that it would take several hundred thousand dollars just to replicate the average Social Security retirement benefit for an average life expectancy. For many retirees, that would be a material portion of their total net worth, it not the largest asset on their balance sheet!
Yet unlike most other assets, the value of Social Security is uniquely impacted by its assumptions… where unlike traditional assets, the value is actually higher when inflation rises, and is greater when interest rates are low. As a result, viewing Social Security as an asset actually reveals that it is a highly desirable asset for a retiree, uniquely capable of hedging many risks in retirement that traditional portfolios cannot… and making it all the more appealing to preserve the Social Security “asset” for its diversification by delaying benefits as long as possible!
The most typical definition of an asset class is a group of securities that have similar risk/return characteristics, and behave similarly in the marketplace. Thus, for instance, stocks, bonds, and cash represent the three most common asset classes, as each have different risk/return characteristics and they behave very differently in response to various economic and market events.
One of the most common ways to attempt to determine whether an investment represents a unique asset class is to examine its correlation with other investments. After all, two investments that have different risk/return characteristics and behave differently in response to market events would likely show little similarity in returns over time, thereby exhibiting a low correlation. In turn, given how Modern Portfolio Theory demonstrates that investments with a low correlation to the rest of the portfolio can lower the overall volatility of the portfolio – even if the underlying investment itself is volatile on its own – advisors have increasingly sought out low correlation "alternative" asset classes and investments to manage risk through diversification.

Welcome back to the 225th episode of the Financial Advisor Success Podcast!
My guest on today’s podcast is Matt Gulbransen. Matt is the President of Pine Grove Financial Group, an RIA in Minnesota that manages over $550 million for about 325 families.
What’s unique about Matt, though, is that despite the widely held belief that direct mail and educational seminars have gone the way of the dinosaur, he has continued over the past decade to see positive marketing results from using direct mail to fill seats at in-person seminar events geared towards educating people about planning for the plethora of life transitions they face as they approach retirement… and then convincing them to work with him to navigate those retirement transitions.
In this episode, we talk in-depth about the ROI that can still be generated from a marketing funnel built around direct mail seminars, Matt’s key realization around why fear-based marketing will only get you so far and doesn’t ultimately help clients move forward to do business, the reason Matt started to charge an upfront planning fee for new clients as he gained traction with his seminars as a means of demonstrating that the work he and his team was doing had value, how Matt has adapted his process in a world where in-person events haven’t happened for a year, and why Matt feels that pre-retirees and retirees are still an attractive target market despite the level of competition in the niche.
We also talk about the way Matt has been able to leverage a relatively lean (at least by industry standards) team of nine people to service $550M of AUM by building out workflows and integrations within their tech stack in order to become ultra-efficient at their most common tasks, why the firm’s desire to focus on tax-savvy household-level allocations led Matt to choose 55IP as their core portfolio management software instead of more popular alternatives, and the various other technology tools that Matt’s firm has implemented to support “tax alpha” as a key value-add they bring to their clients (especially given that Matt and his clients live in a high-tax state).
And be sure to listen to the end, where Matt shares the challenges of starting his career as a young advisor at a wirehouse, how the challenges of prospecting led Matt to shift to the bank channel that had a more captive audience of prospects that could be referred to him, how it was Matt’s initial success with seminar marketing and the realization that he could grow an advisory firm without having a big-name brand behind him that eventually led him to launch his RIA, and how Matt has started to further scale the efficiencies he’s already built in his practice by bringing on outside advisor teams who are able to bolt on seamlessly to his system.
So whether you’re interested in learning how direct mail is still a viable means of attracting qualified prospects, how advisors can still use seminars to demonstrate the value of financial planning, or how Matt has been able to manage a relatively lean team with workflows and automations, then we hope you enjoy this episode of the Financial Advisor Success podcast with Matt Gulbransen.

Enjoy the current installment of “Weekend Reading For Financial Planners” – this week’s edition kicks off with a recent academic study that evaluated the activities that advisors engaged in with their clients in the midst of the pandemic and its market volatility last spring, which found that clients of financial advisors really did appear to sell less and buy more during the downturn, driven in large part by an uptick in proactive communication that advisors engaged in with their clients that helped keep client expectations positive (i.e., that the markets and economy would bounce back soon enough).
From there, we have several articles on the value of financial advice itself, including:
- A reminder that in the end, financial advice isn’t just about helping people identify and set a path towards their goals, but in navigating the complexities that arise along the way (that can block us from achieving those goals, without an advisor’s help to navigate around them)
- A framework to define an advisor’s value across three dimensions of Portfolio, Planning, and Personal (and how to vocalize it in a prospect meeting)
- Why it’s so important to frame a value proposition in terms of how the client benefits, not just the positive traits of the advisor (e.g., “I’m a CFP professional” or “I’m a fiduciary”)
- How the value of financial advice is increasingly shifting towards financial wellness because of the way that money touches virtually everything in our lives
We’ve also included a number of articles focused on improving client communication:
- 6 ‘simple’ but impactful actions that can be taken to show clients that you really care and are thinking about them
- How the Asset Map software helps provide a one-page visualization to simplify a client’s complex financial life
- The power of being a client’s “Chief Empathy Officer” (CEO) when often the blocking points to our goals are mental, not financial
- How a personal finance columnist engaged a financial planner himself to navigate the challenges of his father’s ALS diagnosis, and what she did to provide value to him along the way
We wrap up with three final articles, all around the theme of how we can try to become a little happier and wiser:
- Why it’s how we spend our time (not how we spend our money) that becomes the biggest driver of our happiness and wellbeing
- The incredible impact that a simple compliment can have on making someone happier and more content
- How the path to knowledge is about reading and learning, but also getting the broader perspective that often only comes with trying something and making a mistake, providing a pathway to wisdom through self-reflection and self-correction
Enjoy the ‘light’ reading!