Conflicts of Interest Founders Should Watch For in Advisor Relationships

Key Takeaways

Most advisor conflicts are structural, not personal; they are built into compensation models, firm affiliations, and referral networks long before you show up.
Disclosed conflicts can be managed with the right governance; undisclosed conflicts are dangerous and require a founder level conflict audit, not blind trust in paperwork.
Compensation structures, equity stakes, referral relationships, and dual roles with investors or competitors all shape advice at the exact moments when your decisions carry the most risk.
A coordinating hub, such as a fractional family office or Personal CFO function, can surface and manage conflicts across your entire advisor bench without replacing your CPA, attorney, or wealth manager.
Governance tools like conflict registers, written scopes of work, structured questions, and an Advisor Coordination Audit help founders turn conflict management into a leadership discipline rather than a compliance formality.

Article at a Glance

Most founders assemble an advisor bench one relationship at a time, then assume that “trusted advisor” status automatically means aligned incentives. It does not. The advisory ecosystem that surrounds a five to seventy five million net worth founder was built around product distribution, billable hours, and referral economics, not around your clarity.

Conflicts of interest rarely show up as blatant misconduct. They show up as a steady drift in recommendations toward products, timelines, and counterparties that happen to match the advisor’s compensation grid, firm obligations, or equity position. The impact becomes visible only when you hit a high stakes decision such as an exit, major debt arrangement, or significant insurance restructuring.

This article lays out where those conflicts come from, how they play out in practice, and what a conflict aware advisor setup looks like for a founder whose business is the core of their net worth. It offers a practical four step Advisor Coordination Audit, composite founder scenarios, and a governance lens you can apply across your entire advisor ecosystem.

The goal is not to turn you into a compliance officer. The goal is to give you a clear, founder friendly way to see how incentives around you actually work and to design a system where advice on your most consequential decisions is grounded in your interests, not someone else’s.

Why Advisor Conflicts Are a Leadership Issue

Most founders accumulate advisors as they go. A CPA from a referral, an attorney from a prior deal, a wealth manager introduced by a peer, an insurance producer from the bank relationship. A decade later, you have a bench of competent professionals and no clear view of how their incentives line up with your own.

That misalignment is not usually about bad actors. It is about system design. The advisory infrastructure around five to seventy five million net worth business owners evolved from product manufacturers, financial institutions, and professional service firms optimizing for their own economics. That means:

Insurance carriers and broker dealers built distribution networks that succeed when products move.
Wealth firms built AUM models that succeed when assets stay in managed accounts.
Law and accounting firms built leverage models that succeed when billable work expands across matters and entities.

The result is a landscape where even well intentioned advisors sit inside structures that tilt recommendations in predictable directions. A broker dealer representative who is paid when you buy a product will tend to recommend products. A wealth adviser paid on assets under management will tend to prefer solutions that keep capital in managed portfolios instead of debt paydown or business reinvestment.

For founders, this matters because your business is not one account among many. It is the primary asset, the central risk, and the engine of family wealth. A small misalignment in incentive structures can compound into real consequences in exit timing, after tax outcomes, governance risk, and family alignment. That makes conflict identification and management a leadership issue, not just a technical concern to outsource.

Your Business Is The Magnet For Conflicted Advice

When your net worth is tied up in a privately held business, you are not a standard wealth client. You are a decision maker with:

A concentrated, illiquid asset that will eventually be monetized.
A complex tax posture with overlapping business, personal, and estate considerations.
A financial life where salary, distributions, and business value are entangled.

Advisors in this space understand the stakes. Some respond by building thoughtful, planning led approaches. Others see the same landscape through a product or deal lens. From their perspective:

Insurance producers see key person and buy sell risk and think in policies.
Lenders see collateral and covenants and think in terms of balance sheet structure and fee income.
Wealth advisers see a future rollover event and think in terms of AUM and model portfolios.
Consultants and fractional executives see strategy and governance work and think in terms of equity or retainer.

Each of these perspectives is valid. The problem arises when you treat them as neutral inputs rather than as views shaped by business models. If every advisor you speak with seems to have a solution that matches their shelf exactly, you are not unlucky. You are watching a system behave as designed.

How Misaligned Incentives Shape Decisions You Assume Are Neutral

Conflicts of interest rarely announce themselves. They show up as:

A recommendation to hold an insurance product longer than makes sense for your risk profile, because surrendering it would eliminate ongoing commissions.
Counsel to delay a sale because “the market is not there yet” from someone who earns fees while you wait and has limited upside from a timely exit.
A wealth allocation that overweights proprietary or higher fee products when comparable lower cost options exist.
An estate plan that never gets updated after a recapitalization because no one is accountable for coordinating your legal, tax, and wealth advisors.

These are not usually fraud scenarios. They are patterns where advisor incentives, firm pressure, or quiet referral agreements bend the decision set by a few degrees at exactly the moments that define your long term outcomes. You typically see the impact years later when:

A sale leaves more value on the table than you realized.
A tax bill is materially higher than it needed to be.
Insurance coverage is mismatched to the actual business risk.
Governance documents lag behind the reality of ownership and control.

Research and industry experience both point to a consistent theme: many business owners report regret about their exit and major financial decisions, and that regret often traces back to the quality and alignment of advice in the one to three years before the transaction. You cannot prevent every regret, but you can materially improve your odds by understanding how conflicts shape recommendations ahead of those moments.

Where Conflicts Come From In Modern Advisor Relationships

Conflicts rarely come from a single source. They are layered into the economics of how advisory firms operate. The table below summarizes common conflict sources and how they typically surface for founders.

Common Conflict Sources And How They Show Up

Conflict source	Common advisor type	How it tends to surface for founders
Commission on product sales	Insurance producers, broker dealer representatives	Recommendations tilt toward higher commission products and riders
Assets under management fees	Wealth managers, investment advisers	Preference for keeping assets invested vs. debt paydown or business reinvestment
Referral fees or soft dollars	Any advisor with a referral network	Introductions cluster around reciprocal relationships, not always best fit
Advisory shares or equity	Business consultants, fractional executives, select advisors	Advice on valuation, timing, and deal counterparties influenced by personal stake
Dual representation	Attorneys, M and A advisers, consultants	Advisor aligned with both sides or with an institutional counterparty
Employer or platform affiliation	Captive agents, wirehouse advisers, bank channels	Emphasis on proprietary products or platform partners

A single advisor might sit at the intersection of several of these: a wealth adviser at a large institution paid on AUM, subject to product grids, who also receives recognition for using in house lending or banking solutions. None of this is inherently improper, but it all matters when you interpret their view on whether you should hold more cash, pay down debt, or move forward with a liquidity event.

Structural Drivers Behind Today’s Advice Ecosystem

The present landscape grew out of a product distribution and institutional services model. Insurance carriers, broker dealers, and banks built networks designed to move products and capture client relationships. Legal and accounting firms built leverage models optimized around matters and complexity.

Even as fee based and fee only practices expanded, the underlying structures did not disappear. Many advisers operate inside hybrids: part planning fee, part commission; part open architecture, part proprietary shelf. Referral networks across law, tax, finance, and banking sit on top of this foundation and create informal distribution channels that are opaque to clients.

For a founder, the implications are straightforward:

The advice you hear is filtered through the economics of firms and platforms, not just the professional judgment of individuals.
Disclosures exist but are rarely written or presented in a way that gives you a clean picture of what matters at decision time.
The more complex your situation, the more likely it is that no single advisor has both the full view and the mandate to question conflicts across the ecosystem.

Treating this as a structural reality rather than as a one off concern changes the question from “Is my advisor conflicted?” to “Where do conflicts sit in my system, and how are they governed?”

Disclosed Versus Undisclosed Conflicts

Regulatory frameworks require certain advisors to disclose material conflicts. Investment advisers and broker dealers file documents and relationship summaries that set out compensation methods, affiliated entities, and high level conflict descriptions. These are useful, but they have limits.

Disclosure is not management. A conflict disclosed in a dense paragraph does not cease to exist. It simply moves from unknown to known on paper. The advisor still operates inside the same incentive structure unless something about the engagement changes.

Undisclosed conflicts are more concerning. These can include:

Informal referral economies that do not meet the regulatory threshold for formal disclosure.
Side equity positions held through entities you never see.
Platform economics where firms are paid for distribution or flows that are not clearly visible to end clients.

In these cases, you have no opportunity to weigh the conflict or design safeguards. This is why building your own conflict awareness and governance process matters regardless of how complete the documents appear.

Not every conflict warrants ending a relationship. The central question is whether the conflict is:

Low impact and manageable with disclosure, documentation, and occasional review.
Material but controllable with explicit safeguards such as second opinions or scope limits.
Fundamental enough to misalign the advisor’s interests with yours on the decisions that matter most.

That classification, and the actions that follow, are part of your leadership work.

The Major Conflict Patterns Founders Should Recognize

Several recurring patterns show up repeatedly in relationships with founders at this level. They are rarely dramatic in appearance, but they shape outcomes in ways that become obvious once someone maps them.

Compensation Models That Skew Recommendations

How an advisor is paid is the clearest starting point. Different models create different tilts:

Commission based: Income depends on product transactions. The system tilts toward action and toward products with higher payouts, particularly around renewals, rollovers, and new policies.
Fee based (hybrid): Advisors charge planning or advisory fees but also earn commissions. The planning layer feels neutral, but product selection still lives inside a commission environment.
Fee only, AUM based: Compensation comes entirely from client fees, but income depends on assets under management. The model reduces product bias but can create reluctance to recommend strategies that move capital out of managed accounts into debt reduction, business reinvestment, or large personal purchases.
Flat fee or retainer: Generally cleaner for planning work, but scope boundaries can create blind spots if you assume “they are handling it” when they are not engaged for certain decisions.
Hourly: Reduces structural conflicts though it can incentivize longer processes if not managed well.

No model is conflict free. The key is to understand where each model is most likely to bend recommendations and to apply more scrutiny in those zones, particularly around liquidity events, rollovers, large insurance purchases, and leverage decisions.

Equity, Investors, And Competing Interests Around Your Company

Advisory shares, warrants, and performance based equity are common in the founder world. They are often pitched as alignment tools. They also create a direct financial interest in your valuation, timing, buyer selection, and deal structure.

An advisor whose equity vests on a schedule may be inclined toward decisions that accelerate or delay a sale to match that schedule. An advisor with a preferred position may favor deal terms that protect their downside before yours. If the same advisor also has exposure to a competing company or to your counterparty in a negotiation, the conflict becomes more serious.

These arrangements are not automatically problematic. They do, however, demand explicit governance: clear disclosure, documented consent, and explicit rules about which decisions that advisor does and does not influence.

Dual Representation And Quiet Counterparty Loyalties

Dual representation arises when an attorney, M and A adviser, or consultant has a meaningful relationship with another party to your deal: the buyer, lender, or a competing firm. In formal cases, professional conduct rules require consent. Informal versions are common and less visible.

Examples include:

An M and A adviser who brings the same private equity group into multiple deals and relies on repeat business.
A consultant who advises both you and a competitor on strategy in the same geography.
A lender linked adviser whose business development goals are driven by the institution, not by individual borrower outcomes.

Here, the loyalty line often runs through the party that supplies the most future revenue, not through the founder making a one time decision. That does not mean the advice is useless, but it does mean major decisions should not rest solely on that input.

Referral, Distribution, And Platform Relationships

Referral economics are both common and opaque. Advisory firms often build ecosystems of “trusted partners” and share work through formal or informal arrangements. Platform providers pay for flows or grant advantages for using preferred products.

Signals worth watching include:

Every referral coming from a narrow set of partners across categories.
Vague explanations about why a specific provider is recommended.
Reluctance to discuss whether any compensation or reciprocal arrangement exists.

A clean, expertise based referral usually comes with specific reasons, clear limitations, and transparent answers about any economics involved. Distribution driven referrals tend to be generic and repeat across clients.

What A Conflict Aware Advisor Relationship Looks Like

Identifying conflicts is useful only if you have a positive model to build toward. A conflict aware setup does not assume a world without conflicts. It assumes a world where conflicts are visible, documented, managed, and taken into account on the decisions that matter most.

Principles Of A Modern, Well Governed Advisor Setup

A founder grade advisor structure typically rests on three principles:

Transparency: Every advisor can explain clearly how they are paid, where affiliation lines run, and where their interests diverge from yours.
Documentation: Known conflicts, scopes of work, and consent decisions are recorded in language a non lawyer can understand.
Coordination: Someone is responsible for looking across all advisors and asking how their incentives interact at system level.

This is where a fractional family office or Personal CFO function earns its place. Acting as a planning led hub, it:

Maps the full advisor ecosystem across tax, legal, wealth, insurance, banking, and consulting.
Surfaces overlapping scopes and conflicting incentives before major decisions.
Coordinates the timing and content of advice so that key decisions are not made in silos.

The result is not a replacement for specialists. It is an operating system that makes specialists more effective by aligning their work with a clear, founder centric plan.

Governance, Documentation, And Review Cadence

Governance turns good intentions into repeatable practice. For advisor conflicts, governance typically includes:

A conflict register that tracks known conflicts, who holds them, how they have been disclosed, and what safeguards are in place.
Written scopes of work for each advisor that define responsibilities, compensation, and interaction with other advisors.
A review cadence that brings conflicts back onto the agenda at least annually and before major decisions.

If you have a board, family council, or advisory committee, this governance should not live only in your head. Sharing the structure and key conflict assessments with those groups creates shared accountability and reduces the risk of surprises down the line.

The Role Of A Central Planning Hub

In a fragmented bench, no one has the full picture. The CPA sees tax returns. The attorney sees documents. The wealth adviser sees investment accounts. Each one is competent inside their lane and blind outside it.

A central planning hub fills that gap by:

Holding a consolidated view of business, personal, and family planning structures.
Maintaining the conflict register and updating it when compensation or relationships change.
Coordinating advisors so that cross impacts are addressed before decisions are finalized.

This hub does not eliminate all conflicts, but it does give you a single place where conflicts are visible, debated, and acted on with your interests as the primary reference point.

A Practical Framework For Auditing Advisor Conflicts

The Advisor Coordination Audit is a simple four step process to map, classify, and manage conflicts across your advisor bench. It is designed to be executed in a focused working session and revisited as your situation evolves.

Step One: Map Your Advisor Ecosystem

Start by listing every advisor who has influenced business, financial, tax, legal, or risk decisions over the last two years. Include:

Primary and secondary CPAs and tax preparers.
Estate planning and transactional attorneys.
Wealth managers and investment platforms.
Insurance producers across life, disability, and property and casualty.
Commercial bankers and lenders.
Business consultants, fractional executives, and M and A advisers.

For each, document:

Firm and key individual.
Services they provide.
How they are paid in your relationship.
Any known affiliations or referral relationships.

This inventory is often revealing on its own. Most founders discover that the bench is larger and more intertwined than they assumed, and that they have never seen a simple summary of who is paid to do what.

Step Two: Identify Incentive And Loyalty Lines

Once you have the map, trace the incentive and loyalty lines. Ask, for each relationship:

What are all the ways this advisor or firm earns revenue related to me.
What products, platforms, or counterparties matter most to their business model.
Who else relies on them for work or referrals that might matter in decisions affecting me.

Then ask some direct questions, in writing where possible:

“Can you walk me through every way your firm earns revenue in connection with our relationship?”
“Do you or your firm receive any compensation, direct or indirect, when you refer me to other professionals or products?”
“Are there preferred or proprietary products, platforms, or providers you are encouraged to use?”
“Do you have any equity, carried interest, or other financial stake that would be affected by specific outcomes in my business or in a transaction I am considering?”
“Who else do you advise whose interests might intersect with mine?”

A confident, well governed advisor should be comfortable answering these. Evasive or defensive responses are themselves data points about cultural attitudes toward transparency.

Step Three: Classify Conflicts By Severity And Manageability

With incentives and relationships on the table, classify what you see into three tiers:

Acceptable with disclosure: Conflicts that are real but low impact if understood and periodically reviewed. Example: an AUM fee that slightly favors investment over debt reduction in a context where you have independent input on leverage.
Manageable with safeguards: Conflicts that can materially influence advice on important decisions but can be controlled through specific measures such as second opinions, role boundaries, or written consent. Example: an advisor with a modest equity stake who is walled off from valuation decisions.
Time to reconsider: Conflicts that fundamentally misalign interests on high stakes decisions or that remain undisclosed until pressed. Examples include dual representation in an active deal, undisclosed equity in a competitor, or a pattern of recommendations that clearly favor the advisor’s economics over your objectives.

This classification lets you prioritize effort. You do not need to redesign every relationship. You do need to act on the ones that matter most for your biggest decisions.

Step Four: Design Mitigations And Guardrails

Mitigations should match the tier and be embedded into your ongoing governance, not handled as one off conversations. Common tools include:

Fee restructuring: Moving from commission structures to planning or retainer arrangements where that reduces bias, particularly for planning intensive work.
Independent second opinions: Bringing in an advisor with clean incentives to review recommendations around exits, major insurance restructures, or large allocation shifts.
Scope reassignment: Keeping a relationship but removing the advisor from decision categories where their conflict is most active.
Written consent and documentation: Recording which conflicts you understand and accept, and under what conditions, so expectations are clear on both sides.

When a conflict is severe, entrenched, or combined with poor transparency, the appropriate mitigation is to replace the advisor. That step is easier and less disruptive when you have already mapped your system, documented your concerns, and identified alternatives as part of your governance work rather than in reaction to a crisis.

Applying The Framework In Real Founder Scenarios

The following composite scenarios illustrate how this plays out in practice. They are blended from patterns across many founders and are educational, not descriptions of specific clients.

Scenario One: Commission Driven Wealth Advice Around A Liquidity Event

A founder is preparing to sell a minority stake in a company at a meaningful valuation. Their long time adviser operates under a hybrid fee based model and will earn ongoing fees on any proceeds invested through the firm.

The adviser recommends a staggered sale timeline and a portfolio of proprietary funds and annuities that keep nearly all proceeds inside the firm’s platform. The tax impact of the structure is discussed, but alternatives that would fund debt reduction, business reinvestment, or a different risk profile receive minimal attention.

An Advisor Coordination Audit reveals:

The adviser’s firm has production targets linked to proprietary products.
The adviser has no visibility into the founder’s total leverage or business capital needs.
No independent voice has weighed in on whether the recommended structure matches the founder’s Freedom Point objectives.

Mitigations include engaging a planning first adviser on a flat fee basis to model alternative uses of capital, and requiring independent review of any proprietary or high fee product recommendations before signing paperwork.

Scenario Two: Advisory Shares And Competing Portfolio Interests

A growth stage founder grants advisory shares to a former executive who now serves as a strategic adviser and informal deal guide. The adviser later joins a private equity firm that acquires a stake in one of the founder’s competitors.

When the founder begins exploring a sale, the same adviser offers to introduce the firm they now work with as a buyer. They position it as a friendly deal and cite speed and certainty of close.

A conflict review surfaces:

The adviser holds equity in the founder’s company.
They now also have a professional and financial stake in a competing firm and in the acquiring institution.
Their compensation is tied to closing deals for the buyer side.

In this scenario, the founder:

Documents the conflicts in a register.
Removes the adviser from any role in buyer selection or negotiation.
Engages an independent sell side adviser with no stake in the buyer.

The original adviser may remain involved in operational planning but is not allowed to steer transaction strategy.

Scenario Three: Referral Networks And Quiet Bank Loyalties

A founder’s primary wealth adviser is affiliated with a large bank. Over the years, the adviser has introduced the founder to the bank’s commercial lending team, a preferred estate planning attorney, and an insurance producer in the same network.

The founder notices that nearly every key relationship funnels back to the same institutional ecosystem. A conflict inquiry shows:

The adviser receives recognition and business development credit for cross selling into bank lines of business.
The estate planning attorney relies on the bank channel for a meaningful portion of their work.
The insurance producer is subject to platform grids that reward volume in certain products.

Mitigations include:

Adding at least one independent provider to each category before making new decisions.
Requiring written disclosure of any compensation flows on referrals.
Having a central planning hub separate strategic planning from product and provider selection, then bidding out implementation to multiple options.

How Regulation And Disclosure Fit Into Your Risk Lens

Regulatory standards provide a baseline but do not absolve founders of the need for their own conflict governance.

What You Can Actually Learn From Public Disclosures

Advisers subject to securities regulation file documents that set out:

Services and fee structures.
Affiliated entities and business lines.
General descriptions of conflicts of interest.
Disciplinary history where applicable.

These are useful for spotting:

Mention of commissions, revenue sharing, and soft dollar arrangements.
Complex webs of affiliated firms.
Patterns of product or platform relationships that could matter for your situation.

They are less useful for:

Understanding informal referral economies.
Capturing conflicts that arose after the last filing.
Giving you a clean, scenario specific view of how conflicts interact across multiple advisors.

The most practical approach is to review disclosures selectively for red flags and then use specific follow up questions to convert general language into actionable clarity.

Fiduciary Duty, Best Interest Standards, And Their Limits

Some advisers operate under fiduciary standards that require them to act in clients’ best interests and to disclose and manage conflicts. Others operate under “best interest” frameworks that raise the bar above simple suitability but still allow commissions and proprietary products if certain conditions are met.

These standards matter but they:

Do not require advisers to eliminate all conflicts.
Do not apply evenly across all advisor types in your ecosystem.
Do not replace your need to understand how incentives work in your particular context.

For founders with complex entities, concentrated business value, and multi advisor structures, regulatory compliance is the floor. A disciplined, founder led conflict governance framework is the ceiling.

Frequently Asked Questions About Advisor Conflicts For Founders

Are conflicts of interest always a reason to end the relationship?

No. Almost every advisor relationship carries some degree of conflict, whether through compensation, affiliation, or referral patterns. The question is whether the conflict is understood, documented, and managed, or whether it is hidden and material enough to distort advice on high stakes decisions.

How much extra should I expect to pay to reduce conflicts in my advisory relationships?

You may pay more in visible planning fees and retainers as you move away from product compensation, but you are reducing the risk of paying far more through misaligned decisions, unnecessary complexity, or suboptimal deal structures. The economics tend to be favorable at founder scale, especially around liquidity events.

Is fee only advice always safer for founders?

Fee only structures usually reduce product driven conflicts, especially when fees are flat or retainer based. They do not remove all bias. AUM fees still tilt toward keeping assets under management, and scope limits can leave important issues unaddressed. Treat fee structure as one input, not the only signal.

What specific questions should I ask a prospective advisor about conflicts?

Ask directly about all sources of revenue tied to your relationship, any compensation from referrals, preferred products or platforms, equity interests linked to your business or counterparties, and other clients whose interests may intersect with your own. The clarity and tone of the answers tell you as much as the content.

How should I respond when I discover an undisclosed conflict with a long time advisor?

Start by documenting what you have learned and asking for an explanation. Then assess whether the conflict looks like an oversight or a pattern. In either case, update your conflict register, design safeguards proportionate to the risk, and be prepared to reassign or replace the advisor if you see resistance to transparency or governance.

When does it make sense to bring in a second opinion?

Any time you face a decision that affects exit timing, deal structure, large capital allocations, major insurance changes, or concentrated tax exposure, and a conflicted advisor is your primary source of guidance, an independent second opinion is a prudent step. The cost is almost always minor relative to the risk you are managing.

What should I document internally to manage conflicts over time?

Maintain a simple but current inventory of advisors, compensation structures, known conflicts, and the safeguards in place. Record major decisions, who influenced them, and any conflicts that were active. Share this with your internal leadership or family governance structure so the system is transparent beyond your own memory.

Designing A More Aligned Advisor Bench

Founders who manage advisor conflicts well do not spend their time policing every recommendation. They design a system where conflicts are visible, debated, and governed in a way that matches the scale of their decisions.

A practical starting point is to schedule a focused working session to complete an Advisor Coordination Audit. Map your advisor ecosystem, trace incentive and loyalty lines, classify conflicts, and decide which relationships need structural changes, added safeguards, or replacement. Doing this before your next major transaction or restructuring gives you room to adjust without urgency driving the process.

It is also worth exploring how a coordination first, fractional family office model could sit above your existing CPA, attorney, and wealth manager as a planning hub. A central Personal CFO style function can run the conflict register, manage the governance cadence, and pressure test recommendations across your bench so you are not the de facto integrator of every decision.

If you want a structured, compliance conscious view of your own advisor landscape, you can engage a specialist team to review your current stack, map the patient or client journeys in your business, and assess where automation, nurturing, and advisory incentives intersect. From there, you can run a tailored, conflict aware planning and automation assessment built around your systems, your decision rhythms, and your long term goals, then decide which changes to make now and which to phase in as your complexity grows.

ClearPoint Family Office (CPFO) offers tax planning, consulting, and preparation, as well as estate and business consulting. CPFO does not offer investment advice. When appropriate, CPFO may refer clients to Arlington Wealth Management (AWM), an SEC registered investment adviser, for advisory services. Registration as an investment adviser does not imply a certain level of skill or training, and the content of this communication has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. CPFO and AWM are affiliated entities under common ownership.