outside business activities.
An Outside business activity (OBA) is any employment or compensation from any other person or entity as a result of a business activity, other than a passive investment, outside the scope of work with Core Planning, LLC.
Review and Approval Policy
Investment Advisor Representatives (IARs) are required to report outside business activities to the CCO for review and approval prior to engaging in these activities.
The CCO will review these activities to determine if they create a conflict of interest with the supervised persons’ ability to act in the best interest of the customers. If it is determined that a conflict does exist, the CCO will determine if the conflict can be appropriately mitigated by disclosure or other means.
The supervised person shall provide the following information to the CCO regarding the activity:
Name, address, contact information for the person or entity paying the compensation
Complete description of the activity and amount of time devoted to the activity
Duration of the activity.
Disclosure on Appropriate Documents ( 1A, 1B, 2A, 2B, U4 )
Individual Form U4s and Form ADV Part 2Bs will be updated as needed for outside business activities.
It is the responsibility of the individual supervised person and the CCO to make sure these documents are updated promptly in the event disclosure is required.
Likewise, certain outside business activities of supervised persons may require firm documents to be updated as well. If updates are required for Form ADV Part 1A, Part 1B, Part 2A and/or WRAP brochure, the CCO will be responsible for updating these documents when needed.
Record Keeping Requirements
CCO will keep and maintain records of all OBA requests and any relevant supporting documentation that helped in the decision to approve or deny the OBA.