public communication policy.

Public communication shall include any notice, circular, letter, email or other written communication (including any social media communications, online blog, video, or any other internet communication) addressed to more than one person, or any notice or other announcement in any publication or online media.

Firm Policy

The firm’s CCO shall be responsible for reviewing company public communication and ensuring it is in compliance with jurisdictional regulations. The firm CCO reserves the right to request any post be removed if it is determined to violate the firm's communication policy. In the event of any subjectively grey area, we should err on the side of caution.

Compliance Requirements

Public communication may not:

  • Use or refer to testimonials (which include any statement of a client's experience or endorsement)

  • Mislead clients using misrepresentations or exaggerations

  • Contain possibly misleading use of superlatives (ie: always, never, definitely, guaranteed)

  • Refer to past, specific recommendations made by the adviser

  • Represent that any report, analysis, or other service will be provided without charge unless the report, analysis or other service will be provided without any obligation whatsoever

Additionally, the compliance officer will verify that no public communication contains any of the following:

  • Representations that the communication was approved by a securities regulator

  • Representations that the firm has been sponsored, approved, or recommended by any securities regulator. This does not prohibit a firm from stating that they are a registered investment adviser as long as nothing in the statement is otherwise misleading

  • The initials “RIA” or “IAR” may not be used as they may be confused with a professional designation

  • Any analysis, report, or publication concerning securities, or which is to be used in making any determination as to when to buy or sell any security, or which security to buy or sell

  • Any graph, chart, formula, or other device to be used in making any determination as to when to buy or sell any security, or which security to buy or sell

  • Any other specific recommendations with regard to securities

  • Performance advertising is prohibited

social media.

Social networks connect people via online communities such as Facebook, LinkedIn, Twitter, and others. As with other technology, social networks have proper and improper uses. This policy is designed to help us understand what is required as proper usage.

This policy is directed at and applies to all social networking sites currently in use (e.g., Facebook, LinkedIn, Twitter) as well as any future such sites that may develop during the existence of Core Planning. This policy also covers any other chat rooms, blogs, video sites (e.g., YouTube) or online bulletin boards in which we may be involved.

Core Planning permits the usage of social media websites by its advisers and/or supervised persons for business purposes and has adopted the following policies regarding this usage.

  • Social media site usage is considered correspondence and/or advertising by Core Planning, subject to the above public communication policies

  • Advisers and/or supervised persons are required to notify the CCO of their intention to utilize social media sites prior to usage

  • Usage and posting to these sites must be monitored and approved by the firm’s CCO; and Core Planning‘s books and records policies on correspondence and advertising require that, as correspondence and/or advertising, social media usage and posts must be retained and archived


Supervised persons using social media for personal purposes should follow the following procedures:

  • Follow Core Planning’s guidelines for use of Social Media in reference to any mention of Core Planning

  • Do not hold themselves out as representing Core Planning views in any way

  • Do not post or otherwise comment regarding Core Planning business, clients, employees, policies or any other potentially confidential information

  • Do not “chat” or otherwise communicate with clients or potential clients regarding any actual or potential investment advice

  • Prepare any posts or communications with care and professionalism and ensure they are appropriate in tone and content


In addition, all members should never disclose personal information on any social media website that could allow a 3rd party to gain access to Core Planning’s systems and passwords used for work equipment should not be drawn from any publicly posted information.

Core Planning will periodically monitor the internet, and specifically, social networking sites, for references to the firm. All business-related posts or communications are subject to review and retention by Core Planning. Any violations of this policy will be handled accordingly.

This policy will continue to evolve as new technologies and tools become available and as regulatory requirements change. Where no policy or guidance exists, or if uncertain, Core Planning members should consult with their compliance officer in order to avoid any potential violation.

Every supervised person should acknowledge and sign off on his or her reading and understanding of these policies.

Correspondence 

Core Planning is involved in communicating with its clients in various formats: written letters, email, phone, firm website and newsletters.

In all cases, these communications will either be classified as advertising or correspondence and will follow the appropriate rules and regulations.

Correspondence generally refers to both incoming and outgoing written communications between the firm and one client or potential client. Communications to more than one individual are typically defined as advertising and are subject to the advertising rules and regulations. Correspondence includes both hard copy forms as well as electronic (e.g., email, text message, instant message).