Terms of Service

Note

Section 4.2 describes the AI services as they operate today. Since September 22, 2026, an adviser can choose Grok (xAI Corp.) for an advisor-chat turn, so client information in that turn can reach xAI; the zero-retention check runs on each response, after the request is sent. Google Gemini adds search indexing of documents added to advisor chat; since September 23, 2026, Gemini calls go to Google Cloud's Vertex AI at U.S. endpoints under terms that bar training on the firm's data. Source-code review is removed from the Gemini and OpenAI descriptions, and the description of identifier replacement no longer implies that names are removed. Section 4.1 names the client portal AI assistant, a limited beta whose answers reach the client without adviser review, as the one exception to adviser review of material AI output. "24/7 monitoring" is removed. Section 6.2 describes how clients and staff sign in, in place of a multi-factor authentication requirement. Section 8 is retitled Security Practices, and its breach-notice line gives the Regulation S-P standard of no later than 30 days, subject to the substantial-harm determination. The paragraph on Finalis Securities LLC no longer promises notice of changes to that arrangement. OpenAI voice transcription is removed from Section 4.2; advisor voice-memo transcription was retired on September 25, 2026. Section 16 no longer promises to always email material changes to the AI Services or Security Practices sections: changes are posted with a new effective date, and the firm may also email clients or show a notice in the client portal. Companion to the Privacy Policy effective September 25, 2026 (v3.17) and the List of Subprocessors effective September 25, 2026 (v1.22).