Independent Assessment Report
Kestra Advisory Services, LLC
CEFEX Investment Support Services Certification
Investment Support Services Definition
A fiduciary who is responsible for managing a client’s overall investment strategy, which may include deciding on the client’s asset allocation, developing the client’s investment strategy, implementing the strategy with appropriate Investment Managers, and monitoring the strategy, on a one-time or ongoing basis. The term refers to those who provide specific or comprehensive investment advice including financial advisors, broker-consultants, investment consultants, wealth managers, financial consultants trust officers, financial planners and fiduciary advisers.
SECTION 1 – COMPANY INFORMATION |
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| CEFEX File No.: |
CFX10190 |
| Company Name: |
Kestra Advisory Services, LLC |
| Address: | 5707 Southwest Parkway, Building 2, Suite 400 Austin TX 78735 US |
| Phone: | 844-553-7872 |
SECTION 2 – ASSESSMENT DETAILS |
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| Date of Registration: | 2023.12.14 |
| Assessment Number: | R11 |
| Assessment Team: | |
| Position | Name | Company |
|---|---|---|
| Analyst | Roger Levy | Cambridge Fiduciary Services LLC. |
| Client | Paisley Jones | Kestra Advisory Services, LLC |
| Client | Travis Atkins | Kestra Advisory Services, LLC |
| Client | Keegan Johnson | Kestra Advisory Services, LLC |
CEFEX Registration Committee (CRC)
The CEFEX Registration Committee is responsible for ensuring the consistency, impartiality and technical merit of CEFEX assessments. Members of the CRC may include: Blaine F. Aikin, CFP®, CFA, AIFA® founder and principal Fiduciary Insights, David A. Vriesenga, Senior Partner Vriesport Consulting Services, Roger Levy, AIFA®, Managing Director Cambridge Fiduciary Services LLC and Carlos Panksep, Vice President, CEFEX.
Attestation
The Analyst is independent of the registered firm. He/she has not been employed or compensated by the registered firm for a period of at least 2 years prior and 6 months following this assessment, for the purposes of providing fiduciary consulting services. The Analyst is an Accredited Investment Fiduciary Analyst (AIFA®) and has the adequate expertise and proficiency to perform this assessment.
Purpose and Scope of this Assessment:
To evaluate the Investment Service Provider’s conformance to the practices and associated criteria as defined in the document “Prudent Practices for Investment Support Service Providers” (the Standard) for the declared scope of registration.
The scope of registration is as follows:
Registered Investment Advisor services, including the oversight and support of Investment Advisor Representatives.
Summary of Assessment Methodology:
The assessment requires that the Analyst plan and perform a review of a representative sample of the Investment Service Provider’s (ISP) written records, interviews with appropriate personnel of the ISP and, on a test basis, collect evidence supporting the actions taken by the ISP in providing services to its clients.
Assessment elements include:
- Document review including (as per scope of assessment) Investment Policy Statement, Investment Committee minutes, client performance reports, RFP’s in the selection of service providers, written evidence of Investment Manager reviews, and service agreements.
- Review of arrangements with custodians, brokers and other service providers.
SECTION 3 - ASSESSMENT FINDINGS
The following Practices were assessed within the 3 months prior to the Date of Registration shown above and found to be in conformity.
Show All Details Hide All Details
| No. | Practice | Status |
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| 1.1 | The Investment Service Provider demonstrates an awareness of its own fiduciary duties and responsibilities, if any, and those of the clients it serves. Show Detail Hide Detail | Conformity |
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Detail 1.1.1 The fiduciary Practices and Procedures defined in this handbook are applied. 1.1.2 Representatives of the Investment Service Provider receive training regarding their own fiduciary obligations and those of the client segments they serve. |
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Substantiation
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| 1.3 | The roles and responsibilities of the Investment Service Provider (whether serving as a fiduciary or non-fiduciary) are defined, documented, and acknowledged. Show Detail Hide Detail | Conformity |
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Detail 1.3.2 The Investment Service Provider demonstrates an awareness of, and an ability to effectively communicate, its duties and responsibilities. 1.3.3 The Investment Service Provider acknowledges its fiduciary (or non-fiduciary) status in writing. |
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Substantiation
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| 1.4 | Potential conflicts of interest are appropriately managed. Show Detail Hide Detail | Conformity |
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Detail 1.4.1 Policies and procedures are in place to manage potential conflicts of interest. 1.4.2 Designated senior staff are assigned responsibility to oversee and manage potential conflicts of interest. 1.4.3 Investment Service Providers acting in a fiduciary capacity are not involved in self-dealing. |
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Substantiation
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| 1.5 | Service agreements and contracts are in writing, and do not contain provisions that conflict with fiduciary standards of care. Show Detail Hide Detail | Conformity |
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Detail 1.5.1 Agreements and contracts are periodically reviewed to ensure consistency with the needs of the Client. 1.5.2 Agreements and contracts are periodically reviewed by legal counsel. 1.5.3 Compensation arrangements and affiliations with other service providers are fully disclosed. |
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Substantiation
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| 1.6 | Assets are within the purview of the relevant judicial system and are protected from theft and embezzlement. Show Detail Hide Detail | Conformity |
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Detail 1.6.2 The Investment Service Provider maintains appropriate surety bonds or insurance to protect assets held on behalf of clients from dishonest acts. |
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Substantiation
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| 3.1 | The due diligence process used to select investments is implemented in conformity with generally accepted investment principles. Show Detail Hide Detail | Conformity |
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Detail 3.1.1 A sound due diligence procedure for selecting investment options exists. 3.1.2 The due diligence process is consistently applied. |
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Substantiation
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| 3.4 | A due diligence process is followed in selecting service providers, including the custodian. Show Detail Hide Detail | Conformity |
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Detail 3.4.1 A documented due diligence process is applied to select the custodian and all other service providers. 3.4.2 Each custodian and any other investment service provider that takes possession of client funds have appropriate and adequate insurance to cover losses from dishonest acts |
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Substantiation
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| 4.6 | There is an effective process to conduct assessments of conformity to all fiduciary practices applicable to the Investment Service Provider and, if applicable, to conduct fiduciary assessments of fiduciary clients. Show Detail Hide Detail | Conformity |
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Detail 4.6.4 All fiduciary assessments are conducted in a manner that ensures objectivity and impartiality. |
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Substantiation
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SECTION 4 - ASSESSMENT CONCLUSIONS AND RECOMMENDATION
Based on the findings obtained during the Assessment, the Company is in substantial conformity to the Standard, and is recommended for CEFEX registration.
This assessment has been reviewed by the CEFEX Registration Committee to maintain impartiality and consistency in the registration process. For details on the complete assessment process, please visit www.fi360.com/cefex.
Note to Report
The information contained in this report is a summary of an assessment conducted by CEFEX, Centre for Fiduciary Excellence and is valid for 1 year from the Date of Registration shown. The report is suitable for public distribution at the discretion of the certified firm. For any questions related to this report, please contact CEFEX at cefexadmin@broadridge.com.
CEFEX, Centre for Fiduciary Excellence is an independent certification organization, and is part of Broadridge Retirement and Workplace. CEFEX works closely with industry experts to provide comprehensive assessment programs to improve the fiduciary practices of investment stewards, advisors, recordkeepers, administrators and managers.
Broadridge Retirement and Workplace offers fiduciary education, training and technology solutions, and helps financial intermediaries use prudent fiduciary practices to profitably gather, grow and protect investors’ assets. Since 1999, the firm has provided financial professionals with the tools necessary to act as a fiduciary in their work with investors. Broadridge Retirement and Workplace is also the home of the Accredited Investment Fiduciary® (AIF®) designation, the Fiduciary Focus Toolkit™ and the Fi360 Fiduciary Score®.
