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Compliance

Regulatory calendar, Form ADV tracking, and compliance obligations.

28

Overdue

0

Due within 30 days

3

Complete

Castellano — Charitable Remainder Trust Review

Overdue
Medium

Other

CRT (Charitable Remainder Trust) structure review with estate attorney. Align with annual gifting and charitable legacy goals.

May 30, 2026 (149d overdue)Owner: Al Farmer, CCO

Castellano — Annual Risk Profile Review 2026

Overdue
Medium

Annual Risk Profile Review

Annual comprehensive review — portfolio performance, estate plan update, tax loss harvesting opportunities Q1 2026.

Jun 1, 2026 (147d overdue)Owner: Al Farmer, CCO

Steinberg-Cohen Family — Form CRS 2026

Overdue
Critical

Form CRS · SEC Rule 17a-14

Form CRS delivery required for all retail investors.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Steinberg-Cohen Family — Advisory Agreement 2026

Overdue
Critical

Form ADV · Investment Advisers Act §202(a)(11)

Advisory Agreement required for all active advisory relationships.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Morrison Household — Form CRS 2026

Overdue
Critical

Form CRS · SEC Rule 17a-14

Form CRS delivery required for all retail investors.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Morrison Household — Advisory Agreement 2026

Overdue
Critical

Form ADV · Investment Advisers Act §202(a)(11)

Advisory Agreement required for all active advisory relationships.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Castellano Family — Form CRS 2026

Overdue
Critical

Form CRS · SEC Rule 17a-14

Form CRS delivery required for all retail investors.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Castellano Family — Advisory Agreement 2026

Overdue
Critical

Form ADV · Investment Advisers Act §202(a)(11)

Advisory Agreement required for all active advisory relationships.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Raman Family — Form CRS 2026

Overdue
Critical

Form CRS · SEC Rule 17a-14

Form CRS delivery required for all retail investors.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Raman Family — Advisory Agreement 2026

Overdue
Critical

Form ADV · Investment Advisers Act §202(a)(11)

Advisory Agreement required for all active advisory relationships.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Delacroix Household — Form CRS 2026

Overdue
Critical

Form CRS · SEC Rule 17a-14

Form CRS delivery required for all retail investors.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Delacroix Household — Advisory Agreement 2026

Overdue
Critical

Form ADV · Investment Advisers Act §202(a)(11)

Advisory Agreement required for all active advisory relationships.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Chen-Morrison Family — Form CRS 2026

Overdue
Critical

Form CRS · SEC Rule 17a-14

Form CRS delivery required for all retail investors.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Chen-Morrison Family — Advisory Agreement 2026

Overdue
Critical

Form ADV · Investment Advisers Act §202(a)(11)

Advisory Agreement required for all active advisory relationships.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Washington-Briggs Household — Form CRS 2026

Overdue
Critical

Form CRS · SEC Rule 17a-14

Form CRS delivery required for all retail investors.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Washington-Briggs Household — Advisory Agreement 2026

Overdue
Critical

Form ADV · Investment Advisers Act §202(a)(11)

Advisory Agreement required for all active advisory relationships.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

O'Connell Family Trust — Form CRS 2026

Overdue
Critical

Form CRS · SEC Rule 17a-14

Form CRS delivery required for all retail investors.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

O'Connell Family Trust — Advisory Agreement 2026

Overdue
Critical

Form ADV · Investment Advisers Act §202(a)(11)

Advisory Agreement required for all active advisory relationships.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Nakamura Household — Form CRS 2026

Overdue
Critical

Form CRS · SEC Rule 17a-14

Form CRS delivery required for all retail investors.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Nakamura Household — Advisory Agreement 2026

Overdue
Critical

Form ADV · Investment Advisers Act §202(a)(11)

Advisory Agreement required for all active advisory relationships.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Whitfield Family — Form CRS 2026

Overdue
Critical

Form CRS · SEC Rule 17a-14

Form CRS (Client Relationship Summary) delivery required for all retail investors. Deliver and obtain acknowledgment.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Whitfield Family — Advisory Agreement 2026

Overdue
Critical

Form ADV · Investment Advisers Act §202(a)(11)

Advisory Agreement required for all active advisory relationships. Complete and file to maintain regulatory standing.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Delacroix — FATCA Disclosure (W-8BEN-E)

Overdue
High

Other

FATCA Form W-8BEN-E required for French-sourced assets. Working with international tax counsel — Grunfeld Desiderio. Mapped to Other — no FATCA item_type enum.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Annual CCO Compliance Review 2026

Overdue
High

CCO Review · SEC Rule 206(4)-7

Annual review of compliance policies and procedures per Rule 206(4)-7. Review all client-facing disclosures, conflict of interest policies, and supervisory procedures.

Jun 30, 2026 (118d overdue)Owner: Al Farmer, CCO

Delacroix — KYC Refresh (citizenship docs)

Overdue
Medium

KYC Review

KYC review triggered by citizenship status change documentation update.

Jul 1, 2026 (117d overdue)Owner: Al Farmer, CCO

Morrison — KYC Onboarding

Overdue
High

KYC Review

KYC documentation collection required before account opening. Identity verification and AML screening pending.

Jul 28, 2026 (90d overdue)Owner: Al Farmer, CCO

O'Connell Family Trust — Annual Risk Profile Review

Overdue
High

Annual Risk Profile Review

Annual risk profile refresh — Patrick turned 70 in Nov 2025. RMD analysis required. Last review Aug 2024.

Jul 31, 2026 (87d overdue)Owner: Al Farmer, CCO

Washington-Briggs — Liquidity Event Planning (Series B)

Overdue
High

Other

Pre-liquidity event planning — Series B secondary sale expected Q3 2026. Tax optimization and diversification plan in progress.

Sep 1, 2026 (55d overdue)Owner: Al Farmer, CCO

Washington-Briggs — Form ADV Part 2 Annual Delivery 2026

Complete
Medium

Form ADV

Annual Form ADV Part 2 delivered via client portal. Client acknowledgment received 2026-03-28.

Mar 31, 2026 (209d overdue)Owner: Al Farmer, CCOCompleted: Mar 28, 2026

Form ADV Annual Amendment 2026

Complete
Critical

Form ADV · SEC Rule 204-1, Investment Advisers Act

SEC annual amendment due within 90 days of fiscal year end (Dec 31, 2025). File via IAPD.

Mar 31, 2026 (209d overdue)Owner: Al Farmer, CCOCompleted: Mar 15, 2026

Form CRS Annual Delivery — Henderson Household

Complete
High

Form CRS · Reg BI, SEC Rule 17a-14

Annual delivery of Form CRS (Client Relationship Summary) to Henderson household. Required for Reg BI compliance.

Apr 30, 2026 (179d overdue)Completed: May 6, 2026

Steinberg-Cohen Family — Annual Privacy Notice 2026

Pending
High

Privacy Notice · Reg S-P

Annual privacy notice delivery required under Reg S-P.

Dec 31, 2026 (Due in 66d)Owner: Al Farmer, CCO

Morrison Household — Annual Privacy Notice 2026

Pending
High

Privacy Notice · Reg S-P

Annual privacy notice delivery required under Reg S-P.

Dec 31, 2026 (Due in 66d)Owner: Al Farmer, CCO

Castellano Family — Annual Privacy Notice 2026

Pending
High

Privacy Notice · Reg S-P

Annual privacy notice delivery required under Reg S-P.

Dec 31, 2026 (Due in 66d)Owner: Al Farmer, CCO

Raman Family — Annual Privacy Notice 2026

Pending
High

Privacy Notice · Reg S-P

Annual privacy notice delivery required under Reg S-P.

Dec 31, 2026 (Due in 66d)Owner: Al Farmer, CCO

Delacroix Household — Annual Privacy Notice 2026

Pending
High

Privacy Notice · Reg S-P

Annual privacy notice delivery required under Reg S-P.

Dec 31, 2026 (Due in 66d)Owner: Al Farmer, CCO

Chen-Morrison Family — Annual Privacy Notice 2026

Pending
High

Privacy Notice · Reg S-P

Annual privacy notice delivery required under Reg S-P.

Dec 31, 2026 (Due in 66d)Owner: Al Farmer, CCO

Washington-Briggs Household — Annual Privacy Notice 2026

Pending
High

Privacy Notice · Reg S-P

Annual privacy notice delivery required under Reg S-P.

Dec 31, 2026 (Due in 66d)Owner: Al Farmer, CCO

O'Connell Family Trust — Annual Privacy Notice 2026

Pending
High

Privacy Notice · Reg S-P

Annual privacy notice delivery required under Reg S-P.

Dec 31, 2026 (Due in 66d)Owner: Al Farmer, CCO

Nakamura Household — Annual Privacy Notice 2026

Pending
High

Privacy Notice · Reg S-P

Annual privacy notice delivery required under Reg S-P.

Dec 31, 2026 (Due in 66d)Owner: Al Farmer, CCO

Whitfield Family — Annual Privacy Notice 2026

Pending
High

Privacy Notice · Reg S-P

Annual privacy notice delivery required under Reg S-P. Deliver before year-end.

Dec 31, 2026 (Due in 66d)Owner: Al Farmer, CCO

Patrick O'Connell — RMD Calculation & Distribution

Pending
High

Other

Required Minimum Distribution calculation and distribution initiation for Patrick O'Connell (age 70). Mapped to 'Other' — no dedicated RMD item_type enum.

Dec 31, 2026 (Due in 66d)Owner: Al Farmer, CCO

Annual Risk Profile Review — All Active Households

Pending
Medium

Annual Risk Profile Review · FINRA Rule 2111, Reg BI

Review and refresh risk profiles for all active households. Profiles older than 365 days are flagged as stale. FINRA Rule 2111 compliance.

Dec 31, 2026 (Due in 66d)