AdviserReport is a financial publication operated by Transparent LLC ("Transparent," "we," "us," or "our"), a Washington limited liability company. We publish opinions, in the form of Transparency Grades™, about investment advisory firms registered with the U.S. Securities and Exchange Commission, based on those firms' public regulatory filings. Our purpose is to help consumers understand the conflict-of-interest architecture of advisory firms either before or after engaging with them.
These Terms of Use ("Terms") govern your access to and use of AdviserReport.com, the AdviserReport service, and any reports or content made available through them (together, the "Service"). By creating an account, purchasing a report, or otherwise using the Service, you agree to these Terms. If you do not agree, do not use the Service.
AdviserReport is a financial publication. We publish research, opinions, and reports concerning:
We operate under the publisher exemption to the Investment Advisers Act of 1940, Section 202(a)(11)(D), as that exemption was construed by the U.S. Supreme Court in Lowe v. SEC, 472 U.S. 181 (1985), and as it applies to publications of general and regular circulation that do not provide individualized advice.
AdviserReport is not:
Your access to or use of the Service does not create an investment advisory, fiduciary, broker-client, attorney-client, or any other professional relationship between you and Transparent. Reading a report does not entitle you to advice tailored to your circumstances and creates no obligation on our part to monitor any Advisory Firm, update any report, or notify you of any change.
A Transparency Grade is an opinion, not a statement of fact, and is not intended to be and is not a guarantee of any future outcome. Transparency Grades reflect Transparent's analysis, as of the date of publication, of conflict-of-interest signals derived from data the Advisory Firm itself filed with the SEC on Form ADV Part 1A.
Transparency Grades are published speech on matters of public concern. They concern the conflict-of-interest disclosures voluntarily made by Advisory Firms as a condition of their public registration with state and federal securities regulators. Reasonable people may disagree with our analysis, our weightings, or our conclusions. The Transparency Grade represents Transparent's editorial opinion and is published in that capacity.
A Transparency Grade is not, and should not be construed as:
The Transparency Grade is produced by a defined methodology, applied consistently across the universe of firms covered. A summary of the methodology (including the categories of conflict-of-interest signals it considers, the high-level structure of the scoring approach, and the public regulatory data sources from which inputs are drawn) is published at AdviserReport.com.
The full methodology specification, including specific scoring weights, configuration values, and engine internals, is treated as Transparent's confidential business information. Transparent will provide the full specification on written request to support@adviserreport.com with the subject line "Methodology Request," subject to execution of a non-disclosure agreement on Transparent's standard form.
The methodology version applied to any given report is identified within the report. Methodology may be updated from time to time at Transparent's editorial discretion.
The Transparency Grade is produced by a deterministic, rule-based scoring engine applied to public regulatory data. It is not a machine-learning model output. Identical inputs under the same methodology version produce identical grades.
Transparent does not accept payment from Advisory Firms or IARs to be graded, to receive a higher grade, to suppress a grade, to delay a grade, or to remove a grade. We do not sell ratings, ratings consultations, pre-rating advisory services, or any other services that would influence the issuance or content of a Transparency Grade. Badge licensing, described in Section 3.6, occurs only after a grade has been published and has no effect on the grade.
Transparent does not refer consumers to Advisory Firms. We are not a solicitor under SEC rules. We do not earn referral fees, finder's fees, affiliate commissions, or other compensation contingent on a consumer engaging any Advisory Firm.
The Transparency Grade methodology is determined solely by Transparent. Advisory Firms have no input into, and no advance access to, the methodology, scoring weights, or scoring outputs. Methodology changes are made on Transparent's editorial judgment.
Transparent's revenue comes from two sources: (i) consumer purchases of reports, and (ii) optional badge-licensing fees paid by Advisory Firms that elect to display their published Transparency Grade in their own marketing materials, on the terms described in Section 3.6.
The founder of Transparent is also the principal of NW Straits Financial Services LLC (CRD 315904), a separately registered investment adviser. NW Straits appears in AdviserReport's database and is graded by the same scoring engine and methodology applied to every other registered RIA. The founder has no ability to influence the grade of any individual firm, including NW Straits, because grades are deterministic outputs of public regulatory filings. Any change to the grading methodology applies to every firm in the gradeable universe and is published with version history. Apart from NW Straits, Transparent has no affiliation with, and receives no non-public information from, any Advisory Firm graded on the Service. Compensation paid by graded firms, if any, is limited to badge-licensing fees on the terms described in Section 3.6. NW Straits participates in the badge-licensing program on the same uniform terms applied to all licensees under Section 3.6. It receives no preferential pricing, no methodology input, and no preview or advance access to grades.
After a Transparency Grade has been published, an Advisory Firm whose grade has been issued may separately elect to license the right to display a Transparency Grade badge in its own marketing materials. Badge licensing is offered on uniform terms to any graded firm meeting the licensing criteria; licensee status confers no methodology input, no preview or advance access to grades, and no exemption from regrading on the same schedule and standards applied to non-licensee firms. Methodology changes are not influenced by which firms are licensees. The full terms governing badge licensing are set out in a separate written agreement between Transparent and the licensee, not in these consumer-facing Terms.
Transparency Grades and the underlying data displayed on the Service are derived from public regulatory filings, including:
Information sourced from these public records reflects what the Advisory Firm or IAR filed with the regulator. Where we display data sourced from FINRA BrokerCheck, we identify FINRA as the source.
While we work to display source data accurately and to apply our methodology consistently, we make no representation or warranty that the Service is free of errors. Source filings themselves may contain inaccuracies; regulator data feeds update on schedules outside our control; and our processing of those feeds may itself contain errors. The Service is provided on an "as-is" and "as-available" basis (see Section 11).
If you believe a specific factual element of a report is incorrect (for example, a wrong principal office address, a wrong number of employees, a wrong registration status, or a wrong filing date), you may submit a correction request to corrections@adviserreport.com.
A valid correction request must include:
We will review valid correction requests within a reasonable time and, where the correction is supported, update the displayed data. If the source filing itself is the source of the perceived error, the appropriate remedy is to amend the source filing with the SEC; we display what the regulator publishes.
The corrections process is for factual errors in the data we display. It is not:
Except under a separate written license from Transparent, Advisory Firms and IARs receive no license, express or implied, to use the AdviserReport name, the Transparency Grade name or letter or score, the AdviserReport logo, the methodology output, or any other Transparent content or mark, in:
An Advisory Firm or IAR may, without separate written permission, link to its own published report on AdviserReport.com, provided the link is unmodified and is not accompanied by any claim that Transparent endorses, recommends, certifies, or approves the firm or IAR.
Advisory Firms and IARs acknowledge that all reports are behind a paywall: any visitor clicking such a link will be required to create an account and either purchase the report or redeem an existing credit before viewing its content. Advisory Firms and IARs may not represent that a report or Transparency Grade is freely viewable, that they are providing the report at no cost, or that any link constitutes free or unrestricted access.
"AdviserReport" and "Transparency Grade" are trademarks of Transparent LLC. Unauthorized use will be enforced. Transparent reserves the right to issue takedown notices, cease-and-desist letters, and pursue all available remedies, including injunctive relief and damages.
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Reports are sold individually or in multi-firm bundles. Current prices, bundle sizes, and available tiers are posted on the AdviserReport.com website and are presented to you prior to completing your purchase.
Bundle credits: When you purchase a multi-firm bundle, you may redeem the reports against specific Advisory Firms immediately or reserve them for later. Each unredeemed report in a bundle is held in your account as a credit. Unredeemed credits do not expire and remain in your account until used. The access period for a report begins once a credit is redeemed and the report is delivered, as described in Section 6.6.
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Single-report purchases are non-refundable once the report has been delivered to your account, which occurs immediately upon successful payment. The entire value of a single-report purchase is delivered at the moment of payment, and refund requests after delivery will be denied except where required by applicable law.
Multi-Firm Report bundles may be refunded in proportion to the unredeemed credits, if requested within 30 days of purchase. Once any credit has been redeemed, the bundle is considered partially performed; the refund will be reduced by the value of redeemed reports, calculated at the Single Report price in effect at the time of the original purchase.
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A delivered report remains accessible in your account for twelve (12) months from the date of delivery. After that period, the report is removed from your account and is no longer accessible.
The twelve-month access period reflects the SEC's annual Form ADV amendment cycle: most Advisory Firms file material updates once per year, and a delivered report is a snapshot of regulatory disclosures at a moment in time. After twelve months, the underlying public filings the report describes may have materially changed, and Transparent does not represent the continued accuracy of a delivered report past that period.
Unredeemed credits purchased as part of a Two-Firm or Four-Firm bundle are not subject to this twelve-month period until they are redeemed and delivered. The access period for each report begins independently on the date that specific report is delivered to your account.
Subject to your compliance with these Terms, Transparent grants you a revocable, non-transferable, non-exclusive, limited license to access the Service and view reports you have purchased, for your personal, non-commercial use. You may print or save a reasonable number of copies of reports you have purchased, for personal use, provided you do not modify or remove any notices, marks, attributions, or methodology references.
You agree not to:
We may suspend or terminate your account, without refund, for any violation of this Section 7, and we reserve all other available legal remedies.
All content on the Service (including the design and layout of the Service, all text and graphical content authored by Transparent, the Transparency Grade methodology and scoring algorithm, the Transparency Grade output for any specific firm, the AdviserReport name and logo, and the "Transparency Grade™" name and mark) is owned by Transparent LLC and is protected by copyright, trademark, and other intellectual property laws.
The compilation, organization, and presentation of public regulatory data within the Service constitutes a copyrightable compilation owned by Transparent, even where individual underlying data elements are in the public domain.
Subject to your compliance with these Terms, Transparent grants you a revocable, non-transferable, non-exclusive, limited license to view and use reports you have purchased, for your personal, non-commercial purposes only. Nothing in these Terms transfers any ownership interest in Transparent's intellectual property to you.
All rights not expressly granted are reserved by Transparent.
Transparent does not claim ownership of underlying public regulatory data sourced from the SEC, FINRA, or state securities regulators. The public domain status of those individual underlying data elements does not authorize republication of Transparent's compilations, presentations, methodology outputs, or analytical content.
Our collection and use of personal information is governed by the AdviserReport Privacy Policy, available at AdviserReport.com/privacy. By using the Service, you consent to the practices described in the Privacy Policy.
The Service displays information about Advisory Firms, IARs, and individuals associated with them, sourced from public regulatory records. This information is, by nature of its source, lawfully published and publicly accessible. Display of this information does not require, and we do not seek, the consent of the individuals or firms named.
We do not display nonpublic personal information about Advisory Firms, IARs, or individuals. We do not investigate, surveil, or solicit information beyond what is contained in public regulatory records or other publicly available sources of general circulation.
Advisory Firms and IARs whose data appears on the Service are not parties to these Terms and have no rights or obligations under them. Their relationship with Transparent, if any, is governed solely by applicable law, the corrections process described in Section 4.3, the trademark restrictions in Section 5, and (where applicable) the separate badge-licensing agreement referenced in Section 3.6.
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Without limiting the foregoing, Transparent does not warrant that:
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Sections 2 (the Grade is opinion), 3 (editorial independence), 4 (sources and corrections), 5 (use of marks by graded firms), 8 (intellectual property), 11 (disclaimers), 12 (limitation of liability), 13 (indemnification), 15 (governing law and dispute resolution), and any other provisions that by their nature should survive, will survive termination.
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We may update these Terms from time to time. The updated Terms will be posted on AdviserReport.com with a new "Last Updated" date. Material changes will be communicated by email to your account email address or by prominent notice on the Service. Your continued use of the Service after the effective date of any change constitutes acceptance of the updated Terms. If you do not agree to the updated Terms, you must stop using the Service.
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