RubinBrown Team Member Manual

Fiduciary Relationships 1215

Policy Title: Policy Number:

Section:

Risk Management

Effective Date:

Supersedes Policy Dated:

06/01/2024

06/01/2023

Policy: RubinBrown and Affiliated Entities: Neither RubinBrown LLP nor any of its affiliated entities are to be named as fiduciaries for any clients or non-clients. Responsibilities related to serving as co-fiduciaries through RubinBrown Advisors in the normal course of business for benefit plan and other clients are excluded from this prohibition, as are situations in which the Firm is named as a court-appointed trustee for a client and indemnification is received. Partners and Team Members: No partner or other team member of RubinBrown or its affiliates shall serve in the capacity as a primary or successor fiduciary for any client (client situations) or non-client (non-client situations), except for in those situations specifically allowed below, including by way of example but without limitation, acting as a personal representative, executor or administrator of an estate, as a trustee of a trust or as a director of a corporation without explicit written permission of the Board. It is the Firm’s general policy that partners and team members shall not serve in such roles. Permission will be given only in certain situations at the discretion of the Board. In such instances the partner or team member must agree to the following: Client Situations: 1. The Board must give explicit written permission to allow the partner or team member to serve in a fiduciary role. 2. Such relationships must be disclosed in the annual firm wide disclosure process. 3. All fees or other compensation for service are to be paid to the Firm directly or turned over to the Firm. 4. An engagement letter must be signed by the client acknowledging and waiving any potential or perceived conflicts of interest regarding other services provided by the Firm. 5. Partners and / or team members serving in fiduciary roles may generally not serve the same client or client group in any other capacity, including but not limited to, providing tax return preparation, financial statement preparation or tax consulting services. 6. Adherence to the AICPA Code of Conduct, Circular 230 and any other governing regulation or rule shall be strictly enforced.

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