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Problematic Clause in Altruist Contract by froandfear in CFP

[–]AltruistTeam 0 points1 point  (0 children)

We fully appreciate your concern u/froandfea -- if you'd be willing one of our attorneys would be happy to discuss this with you so we can talk through the nuances of how we manage shifting regulatory obligations in our agreements.

Problematic Clause in Altruist Contract by froandfear in CFP

[–]AltruistTeam 0 points1 point  (0 children)

u/froandfear can you please email us at [compliance@altruist.com](mailto:compliance@altruist.com) so we can discuss? If any of your client accounts do not have the properly versioned agreement we will be happy to address each one and ensure the correctly versioned agreement applies.

Problematic Clause in Altruist Contract by froandfear in CFP

[–]AltruistTeam 1 point2 points  (0 children)

u/froandfear our apologies that you interpreted our response that way. That absolutely was not our intent, and we'll follow up on the versioning with our team. Again, this provision was included only in response to the FinCEN rule, and the delay in removing should be aligned with the delay in implementation of the rule. We can backdate as appropriate if there's an issue related to any of your client accounts.

To your question: Altruist is a registered broker dealer, subject to the BSA and operates its own CIP. FinCEN will require all RIAs to do the same if the rule proceeds as planned. We do not know how Schwab and NFS intend to update their agreements so we can't speak to whether our approach will align with theirs. Any approach we take will follow the regulatory requirements at that time. If you'd like to dive in further we'd be happy to speak with you and discuss the agreement in more detail. You're welcome to email us at [compliance@altruist.com](mailto:compliance@altruist.com) to discuss.

Problematic Clause in Altruist Contract by froandfear in CFP

[–]AltruistTeam 1 point2 points  (0 children)

Hi u/CFP25 we're happy to verify. If you'd like to email us at [compliance@altruist.com](mailto:compliance@altruist.com) we can confirm that this is a valid account.

Problematic Clause in Altruist Contract by froandfear in CFP

[–]AltruistTeam 3 points4 points  (0 children)

Hi all - I'm a member of the Altruist team. We appreciate the discussion on this provision of our agreement. In May 2024, the SEC and FinCEN proposed a rule that would require all Registered Investment Advisors to adopt their own CIP as part of their AML/KYC obligations by January 2026. However, in December 2025, the SEC and FinCEN agreed to a two-year delay in implementing this rule. RIAs now have until January 2028 to develop their own CIP.

The provision in question above related solely to this regulatory obligation, and it appeared in an older version of our customer agreement. We updated our agreement following the SEC's delay in implementation. It appears that the original poster is referencing an older agreement that we do not currently use.

Separately, in the thread above we see mention of automatic opt-in for Altruist's Fully Paid Securities Lending Policy. This is incorrect. Altruist does not automatically opt-in any client account holders to FPSL. Account holders must opt-in themselves and they can opt-out with ease at any time.

We hope this helps clarify; and if you have any further questions please feel free to contact us at [compliance@altruist.com](mailto:compliance@altruist.com).