Registered investment advisors, how much should you disclose when you use articles written by others? Is it okay to slap your name on articles largely written by others? What if those articles may also appear under the names of other advisors?
Below is a question posed by one of my readers.
Several DFA staff members write commentaries which are kept in a “library” for the approved advisors to use. Approved advisors can search for a commentary that they feel is timely (not usual to see commentaries which were written by DFA in 2008-2010 used in the present by an RIA).
A simple search of an DFA used commentary by an RIA will bring up multiple “DFA-approved RIAs.” However, in the individual RIA commentaries a few will use a disclaimer that states the subject matter was “Adapted From Joe Smith of Dimensional Fund Advisors” while many others will treat the commentary as their own work.
RIAs are quick to market their role as a fiduciary to their clients but I feel that acting with integrity is just as critical. I believe that citing sources correctly is fundamental to acting with integrity when communicating with clients and the public.
Do you think that clients would appreciate such disclosure and conversely disapprove of portraying another firms thoughts and research as originally from an RIA?
This isn’t–or shouldn’t be–an issue for registered representatives because FINRA advises them to disclose the role of other writers, as I discussed in “Registered reps, it’s time to ‘fess up.”