Hello, I'm Kylie Beach, General Counsel at Orion, where I oversee our legal, compliance and risk teams. I've had the opportunity to work with Orion for the past 11 years, and during my tenure I've had a chance to work with not only our internal compliance team members. But also to hear from an interact with so many of the compliance professionals using our technology and services across our platform. So I'm particularly excited about the subject matter we're going to be discussing with you today. I'm also honored to be joined today by Lewis and I'll let him give you a background on himself. Hi, I'm Luis Giannini, Director of Product for Compliance here at Orion, and I'm excited to talk to you today about our new game changing technology. All right, throughout our webinar today and before we allow for Q&A, we want to tackle 3 main objectives. First, we know that some of you may be new to Orion's compliance technology and maybe even new to Orion in general. So we want to take an opportunity to help you understand our expanded capabilities. And particularly because they've expanded so much over the last couple of years, help you understand what we're doing to power the advisor client journey. Next, we're going to review with you the rationale and really the catalyst for building our latest innovative solution for regulatory compliance, which we term the client oversight tool and 3rd and probably the most important piece of today's session. Is going to be turning it over to Lewis. So you can actually see a demo of the tool which I know will be way more impactful for you to see as opposed to just hearing us talk about it. So moving into the next slide at Orion, we like to think about our wealth tech offerings as a collection of powerful tools that work seamlessly as what we term the fiduciary flywheel and that fiduciary flywheel is really. What powers the advisor client journey? We know that that journey includes many needs from both the advisor and the client perspective, beginning all the way from the time that you're first introduced to that client as a prospect, all the way through the important financial planning and investing stages of your relationship and continuing to offer you tools that really help you expand and build on that relationship over time. We are focused on offering best in class integrated technology at every step of your journey with your clients and we also know that the importance of our services. We also know that our services are important to allow you to scale and to tackle real pain points that can prevent you from doing what you do best and that's focusing on what's best for your client. And I think it's this notion of tackling pain points that first led us to wanting to create powerful compliance technology to power your firm's compliance program, right. This brings us to today, why compliance oversight and why are we focusing on this particular offering? So for many of you and again, I have the opportunity to speak to to you and I see the challenges today in my own role at Orion. But we've entered into a very tough regulatory environment, perhaps for many of you may be the most active SEC you've seen in your tenure. And these pain points are real and they continue to be seen throughout industry headlines and throughout the many examinations that our advisors are facing with. And we also know that every firm has unique compliance risks and challenges, but all firms come to us. With a very important shared goal of wanting to improve regulatory compliance and being prepared for that for that next SEC exam, in 2022 alone, we saw 6.4 billion in monetary penalties leveraged by the SEC. That's the highest number of record and importantly almost double what they did in 2021. Why is that important? It's important because. Not only is that number high, but if you look at the most actions that being that are being brought in 2022 and who they're being brought against, it's unfortunate that RIA's and investment companies are at the top of that list. And so we know that the regulatory challenges are real. We know that it's not a matter of if, but when you will be sitting across from the SCC. And we remain committed to partnering with you to help tackle the compliance challenges that you face and to increase the confidence when the SEC does come to know that you're doing everything you can to not only maintain your compliance program, but continue your important mission of doing what's best for your clients. And it's against that backdrop that we really sought to create solutions for CCO's that tackle some of the most important challenges that you have perhaps because. Those challenges are tied to manual processes to control compliance risks, and perhaps because no other solutions existed or have existed until this point to help you manage those compliance risks. And it's against that background that I'm excited to turn it over to Lewis to tell you more about the client oversight tool. All right, so as Kylie mentioned having a range of complex, manual, disparate processes. Only potentially increases your firm's risk exposure as well as allows unnecessary complexity. So when evaluating a potential Reg tech solution, we need to look at it through the lens of what's most comprehensive, effective and efficient. And when looking back, you know prior to the acquisition of Basis Code which is now of course Orion compliance. There are always a consistent number of pillars, if you will, that made-up sort of a Reg tech pyramid throughout history. So for example, firm oversight, right? Being able to monitor your firm, whether it's code of ethics, amlkyc quizzes. Compliance manual acknowledgments or even testing the controls that make up your compliance program. So think of best X. Think of a DV. Think of e-mail check, right. So firm oversight was always present and it carried a long proven track record of success. But just as instrumental to firm oversight and of course complementing it was employee oversight. So this is your personal trade monitoring right? Preventing potential front running looking for a proper advertising review. So firm oversight and employee oversight were two very robust pieces and they did very well for a really long time. But there was always a piece that was simply beyond our grasp. It was just missing. And it wasn't until, you know, we started to hear additional feedback from clients who came up to us and said, hey, look, I'm being audited. I've been flagged on a range of items, one of the most significant recommendations. Was to strengthen my client focused compliance, for example, choosing the most appropriate share class for a client and they would come to us and say you know is there a better way that we can do this? Is there any way we can streamline it? We have spreadsheets everywhere, we have turnover, it's it's quite chaotic. You know how can we simplify and streamline this process? And our answer was a resounding yes. Because we believe that delivering Reg tech that's proactive is paramount not only to our success, but that of our clients and their compliance program and that's where client oversight came to be. So the driver, the catalyst for client oversight of course were client needs. But it really became the capstone, the bookend to that Reg tech pyramid that now allows us to offer unprecedented Reg tech that covers both firm employee and client oversight. So we're extremely excited because we now have a full end to end workflow solution that'll cover firm needs, employee needs and now client focus needs. And we're going to dig into the particulars in a minute. So we'll get to see all the fun stuff, but that's what's interesting to me about how client oversight came to be. So I want to move on towards what exactly is client oversight? What does it contain? What does it do? Client oversight of course, is a game changing new module within Orion compliance. And what's remarkable about this module is its breadth in depth. It's the amount of functionality within it. That really makes it interesting. So a range of high impact processes that you can streamline and automate, remove the guesswork, remove the spreadsheets. That's going to save time and of course improve accuracy and give you a full end to end workflow experience from one application. For example, client trade preclearance. And this is one of the first areas where we really see the Orion ecosystem being highlighted, right. So one of the main drivers of client oversight. Of itself was leveraging the synergies of the Orion ecosystem. It's plain and simple that additional horsepower, that additional technology is what allowed us to drive towards all of these unique integrations and features and functions and client trade preclearance is no exception. So firms that use Eclipse, right, if you're going to go place an order in Eclipse. Your traders can now get real time outcomes based on rules that you've set up within Orion compliance. So think of your inverse or leveraged ETF rules. Think of asset class restrictions, product restrictions, Maybe you restrict fixed income, maybe you restrict equities. Whatever the case is, all of that can be accommodated. Think of shortterm trading rules when you're trading the same security in the same account within N number of days. Think of trades based on market cap or approval list. So this is just a preview of some of the capabilities within client trade preclearance. But what makes it the most interesting is that it really carries a you know, A2 app integration where you have Eclipse on one end, Orion compliance on the other and they work seamlessly together to provide that streamline automated experience. The 2nd is share class review. So shared class review is actually one of the most nuanced, most complex processes out there. We all know that. You know, we've heard this from clients ad nauseam and we've heard you loud and clear, right. We understand how difficult it is to keep track of it. We understand how difficult it is to document. And you know, one solution of course is to just increase scale through head count or to add more spreadsheets. But what we've done is we've partnered up with Risk intelligence, we've integrated with Risk intelligence. We're able to streamline that process in one location within Orion compliance. So not only can you see a potentially less expensive share class, but you can also document what's most appropriate for your client and why we then get to ownership alert. So this is your standard 13DR G So these are event driven alerts of course when your firm requires more than 5% of a public company shares. And these are also again powered by risk intelligence. So we're really starting to see a pattern here of the Orion ecosystem and you know how it comes into play and how it adds value throughout each of these different integrations. One thing that all of these have in common, client trade, preclearance, share class ownership, large trader, they all carry the hallmark of Orion compliance which is end to end workflow. And on demand reporting and we're going to get to dive into this in a moment. But I just wanted to point out that each of these things are actual action items that compliance or any other associated group from your firm that you choose, maybe a supervision group, maybe another group have the ability to go in work individually or as a team, document their outcomes and then extract them for reporting large trader alerts 13 age. So of course the system's going to generate alerts again with full workflow, and this time it's going to align with the 13 H threshold, right? So if you think of transaction amount and volume, 2 and 20 million in a day, 20 and $200 million in a month, when your client trades, which by the way come in automatically from Orion compliance, it's simple checking a box to get all those trades in. The system will do all of the heavy lifting, normalize that data and then when and if a 13 H alert is available, just simply generate it for an assigned approver who can jump right on into the action. And then last but not least, and one of my one of my favorite. If I'm being a little bit biased, our risk monitor updates and the reason that this is so important is because the way I'd sum it up is it takes an eye in the sky approach. The client account monitoring. So think of high cash, think of low trade volume. You have a variety of parameters that you can configure tailored to your firm's policies. And what the system will do is it will actively and continuously monitor all of those client accounts and point out to you when and if an account breaches A threshold, how many accounts are impacted, and then provide for you underlying queries to perform your due diligence. And just as exciting, although arguably some some of you out there may say it's more exciting and again we've heard you loud and clear portfolio drift tracking will be part of the risk monitor and not only will it be able to account tracking at the registration level, but it will also be able to track tracking at the household and account level. So enough of me talking, I know we want to get into the good stuff. So let's dive in and take a brief demo through client oversight all right. Let's take a deeper dive into client oversight. We're going to walk through a brief demo So what you're looking at right now on your screen is the landing page. The home page. The dashboard for compliance where all of the action items that require your attention are going to jump out to take you directly into the workflow, but we're going to focus on client oversight. The newest addition the newest module that's just been added to Orion compliance. We're going to go through each of the different areas and of course as you see things that catch your attention, feel free to submit any any questions as they come to mind. So talking about client trade preclearance and how it's powered by Eclipse, one of the most interesting parts about client trade preclearance is being able to set your policies, your rules. So for example, rejecting leverage or inverse ETF's product restrictions. Approved, approved list, restricted list. And what you have the ability to do within the tool is use off the shelf, out-of-the-box policies or you can configure your own custom policy. So suppose we wanted to make a policy that, you know, restricts inverse ETF's, right? It's an extremely straightforward experience because what we're going to do is enter some basic information. Such as you know what's shown to the trader when the trade's rejected the name of the policy, what it's going to do on the outcome when some meets the criteria, in this case auto reject. And then we're going to get to decide how does this policy apply, who does it apply to? So by default of course the policy would apply firmwide, but you have the ability to say, hey, I want this policy to apply to a specific team with an eclipse, a specific trader or traders. Models and or Accounts. And what's great about this functionality is that all of these values that you see are pulled in directly from Eclipse. So you don't need to reinvent the wheel. Manually enter in text, It's all going to automatically pull directly into your policy engine. You then have the ability to incorporate security list. So think of your restricted list or an approved list. You can simply upload a list of securities within Orion compliance. Select that list and any trade placed in Eclipse that is equal to that security will then meet your outcome. For example, it might be auto rejected. If you'd like, you can also ask the system to look at the issuer level as well. So it's not just looking at IBM, it's looking at all derivatives of IBM bonds, so on and so forth. When that trade is placed, you can also make product type restrictions. So again. All of the products that you currently maintain an eclipse will also show here where you can say for example, I'd like to auto reject all bond trades or all C D's or whatever the case is so you can individually or add in bulk any of the security types that you see fit to implement that restriction. But if you want to get more granular and you have more complex or more nuanced rules, you have two areas here at your disposal. One is trade detail triggers. So what you're looking at essentially is a broad list from the order details screen in Eclipse where you can specify one or multiple conditions that you think the policy needs to meet. So for example, if I wanted to focus on all buys, I could accomplish that. If I wanted to focus on all buys in combination with a custodian or an account type, I can select that and I can choose that. Each of these conditions is required or that any of these conditions is required. So again, really intuitive and straightforward being able to tailor these specific policy rules around your current processes and procedures. But we've been talking about restricting ETF, so in the system it's really simple and easy to do so because all we would need to do is select. From this list of market data points and of course we're going to have other data points like on industry, currency, domicile, market cap. But if we look towards the inverse leveraged item, we would simply select it, choose the condition and say when the trade being placed is inverse auto reject it. So it's that straightforward to configure your rules. And again, if there's other qualifiers or criteria, you could simply add an additional line item word two or three, however many are required to create that policy. So as we move down further, we also have the ability to monitor for conflicts of interest. So think of somebody placing a trade. Where somebody within your firm may have a board seat or any type of board commitment that they've disclosed as an outside of business activity, the system will make that connection. You then have the ability to monitor for short term trading. So think of being able to trade the same security in the same account, let's say within two days where you can select how many days what the business method is and make that comparison again to generate an item for preclearance. And last but not least is the policy validation. So this is a really important section because this allows you to enter a fully functional and fully fictional trade ticket to test the policy that you've entered. So in other words, hey, I've gone through this, I've set up all the rules that I think are right that needs all the boxes that need to be checked. But when this happens in real life, what's actually going to happen? That's the power of the policy validation, which would give you a result saying this trade would be auto approved or auto rejected on this basis, and explain why. So once the rules are set, of course the trader in eclipse is placing that trade, and when that trader is placing the trade, there's going to be one of three outcomes. The trades either going to be automatically approved or rejected, in which case the workflow ends there. If it's approved, the trader moves on and executes. If it's rejected, the trader needs to put it in a new trade. Scenario #2 is the trades rejected, but this time the trader appeals the trade, so the trader says hey, I don't agree with the decision the system made, but I'm going to give you a reason why. So when that happens, what you're looking at is the action item, the appeal that compliance would see. And right off the bat, we noticed something that's very apparent. 2 questions come to mind. What am I looking at and why? So what you're looking at here is a trade request that was appealed for IBM. Why you're looking at it is because I, BM in this case, was on a restricted list. I can see all of the pertinent information about the trade. I can also see the reason for the appeal from the trader. If I expand, there's additional information again on the trade itself as such as who made it, what model, what account, and so on. If I go down further, I can then see the system summarizing for me why I'm looking at this. Again, Policy was restricted list fail, so we know that this trade was on the restricted list. And then we're able to jump into the workflow, there's that word again, jump into the workflow with one or multiple people that we've assigned. So we have the ability to do this in a linear fashion where all people need to approver or any end number of people can approve it. And we would simply be able to approve or reject the trade where the trader will receive an e-mail notification and be able to carry on forward to then execute that trade. So over time, right, there's going to be a whole range of different trade requests, right? There's going to be trade requests that are approved, rejected. So what's important about that, right? What's important about history? What's important about history in our view, is being able to quickly and easily find the data that you want, that you need in an intuitive fashion. So that means being able to drag and drop columns. That means being able to add or remove columns. That means being able to search and sort on different things. So for example, let me see how many trade requests met a certain policy so I can get an idea of which policies are being impacted the most. But last and just as important is how do I get the data out, right? So you get that letter in the mail for a regulatory request or maybe it's an internal e-mail and you need to produce the last couple quarters, maybe the last year, whatever the time frame is. Of trade requests. So in the system you can export on demand. The data is yours. You can export into a classic excel sheet a CSV, which is also of course in Excel, but the most comprehensive is the zip export. So what this does is it will download all of the filtered items. Directly to your computer and each of them will have their own separate folder providing a full audit trail of all of the workflow within the action item, who approved it, when they approved it, all of the information on why the trade was rejected, all of the trade information and of course any attachments that also may accompany that action item. So we have this whole concept here of of easy data maintenance, easy data filtering and then on demand robust reporting. And talking about ownership in large traders, so right this is also part of the client oversight module. So ownership in large trader again lends itself to ownership being beneficial ownership. You're 13DR G where you can say hey if our firms acquiring more than 5% of a security, in this case over 6%. What does that mean in real terms for shares and how many shares are outstanding, that security we need to be notified. So once again, what we're looking at is an ownership threshold that was exceeded for EVBN. And here's why, because it was over over 5%, we have the system then creating a timeline that can be captured for a workflow and eventually wrapped up and delivered into a report again internally or for a regulator. So we have the ability here to add findings. This would be your most meaningful addition. You know what was the outcome? Was there any issues where there are no issues, if there were issues. So severe were they Can I add an attachment? Can I document things further? I can also add a comment which is very similar, but my path of action here is to mark it complete. So once I've looked over things, once I'm comfortable with the stage of the workflow I can simply complete the item and it will fall off of my To Do List as well as any other colleagues who are also assigned as approvers for that item. Talking about large traders so. If we go to a large trader trader alert, we mentioned earlier that the system is going to look at daily volume and daily amount as well as monthly volume and monthly amount. So right off the bat, what are we looking at? A daily large trader threshold was exceeded on July 7th, 2022. Why the transaction amount exceeded 20 million because it was 27 million plus. So being consistent, the system generates a nice clean descriptive workflow and allows one or multiple people that we assign to add their findings, comments and then eventually mark complete to be searched for later on in your history and also of course exported for reporting purposes. So I want to talk a bit about the risk monitor. You know, as alluded to before, the risk monitor currently exists, but we are excited because there's a whole range of different enhancements and upgrades that we're looking at making. But here's what you can do today. Right now you have the ability to set different parameters. So for example, high cash, low trade volume, you have the ability to control these parameters, in this case 50%. You can make this five percent, 10%, whatever you choose. And then the system's going to show you all of the impacted accounts within Orion Connect on an ongoing basis. So you could come in here at any time and say, hey, we have X amount of accounts exceeding cash at this percentage. We need to learn more. How do we do that? You're able to quickly and conveniently click on the item and what's going to happen is it's going to load all of the underlying affected accounts. So you can conduct your investigation and review further within Orion compliance to see where things are and decide what next steps might be when going back to Orion compliance. I want to point out that the risk monitor, of course it has account focused alerts now, but in the future it will also incorporate portfolio drift which again will be at not just the registration level as it can currently be done today. But also at the account and the household level, we know how much this has been a request from our clients. And again, we've listened and are excited to deliver this new update. So we've talked about client trade preclearance with Eclipse. We've talked about ownership and large trader powered by risk intelligence. We've talked about the risk monitor also in part powered by risk intelligence. So now we want to talk about share class, right? So share class review how that works. So let's go to share class and let's start talking about what this experience looks like. So some of you have come to come to us and said, hey, we do this twice a year. We send a list of funds to our reps, We need them to review it and we need to do this in a more streamlined way. So what's the best way that we can do this? So what we're looking at here is a list of funds that would be sent to, let's say, a Rep at a predetermined frequency. You might choose to do it once a year, twice a year, monthly, quarterly, whatever is the best fit for your policies and procedures. But what's happening is the Rep is looking at this list of currently held funds for their clients and they're prompted to simply make a recommendation. Do we stay with the current fund? Or do we go to a potentially cheaper fund, assuming it's more appropriate? And of course, they have all the pertinent information, how much is invested by a client, what custodian the current fund is held at? And when they drill into that, what they're able to see of course is expanded information. So what security are we talking about? In this case, we're talking about PXWGX. We're able to also look at how much money is invested across that fund for all clients involved. How many accounts are eligible for this current fund? What shared class is the fund, and of course, which custodian is it held at? So this is where the Rep is able to take action. They're prompted to make a recommendation, and what they're looking at here on the left is the current fund. They hold all of the key information about that fund, what accounts are holding this fund, as well as all of the key metrics with. Net and gross expense ratio, 12B1 sales load, transaction fees when they're available and of course notes from the custodian, they're comparing that against one or multiple potentially cheaper funds, which would show up of course. In this example here, we're looking at PWGIX so the Rep can stay with the current fund or they can choose to go to a potentially cheaper fund by making this recommendation. And when they're making the recommendation, they're actually going to be prompted on why they're doing it, and they need to be prompted in a concise, direct fashion. The great part about this is that these values are customizable by compliance, supervision, or any other equivalent team. So you may choose, when you set this up to say we're only going to allow one choice or going to allow five choices and they're going to be these. So in this example, we could simply say we believe this is most appropriate for the client. We can add additional comments if necessary, but of course they're optional and then we can submit. Once we do that, the workflow will be updated. The reps spot is complete, they no longer need to do anything. So at this point the Rep has done their part in the workflow. So what does this look like from the compliance side of the world or from the supervision side of the world? So once Compliance logs in back into a Ryan Compliance, we'll put our compliance app back on. Compliance is going to be greeted with the dashboard item just like this where they're going to be able to click into their share class review and they're going to be able to see all of the reps they've sent it to and how many recommendations they've made and for what. So in this case, we can see that this Rep is proposing to exchange to PWGIX. We're prompted here as Compliance to go in and sign off. Which we can do individually by drilling down. We can see the recommendation that was made. We can see the timeline of what was being added here and we can simply go in and view the recommendation, choose to switch it or just simply approve it based on what the Rep has entered. So in this case, we've approved it. We've now completed the workflow. And again, we also have the optional ability to add findings or comments. So eventually what's going to happen with this workflow is over time, compliance is going to review everything from a Rep and it's going to look like this. So they'll be able to see Okay. I've reviewed this from this Rep, I've reviewed this one from this Rep In this case, they want to exchange, In this case, they want to stay with the current fund. In this case, I still need to review, and in this case, I'm waiting on the Rep. So here's really where you really get to own oversight. You have a full holistic picture of what the Rep is reviewing, when they're reviewing it and what the outcome was. Now over time, these reviews are going to accumulate. So what does reporting look like? Reporting is in the same fashion that we've seen with preclearance and ownership and large trader. You can fully export this grid to a CSV, excel sheet or zip package. And you can do so by item. So you can select one or multiple items and sign off on them in bulk as well as individually like we've seen. But you can also export things in an itemized fashion or everything at once. Now over time, you might say, well, what good is exporting one of these reviews if? I need to export the last 10 or 15 for a regulator. It's going to be quite time consuming for me to come in here and manually export each one, and that's a valid question. So what you're able to do is look at a history of all of your reviews and then export them here at this level again into a spreadsheet or into a zip package which would contain all of the underlying information including recommendations made, audit history and workflow, as well as any attachments, findings and exceptions. It's worth noting that with shared class, you know we're we're looking at this from the perspective of sending it to a Rep but it's worth noting that this process can also be done in a centralized fashion, which means that it's not sent out to reps. So you have the ability if you have a supervision team that's carrying this out internally and they're not sending it to reps and that's not your current process that can also be conducted directly within Orion compliance. And it would look simply like this. So it would be almost the same exact identical workflow, except in that case it's not being sent to the reps, but you still have the same exact functionality where you can assign one or multiple people to approve. You can make a recommendation. And of course, whether you're sending it to reps or not, you also have the ability to tailor settings around your review. So certain variables that you may have with your process, such as an approved list, can also be incorporated prior to launching a review, so that your review is tailored to your current workflow and your current processes and procedures. So that's the overview of client oversight, right? I don't think there's an argument that it's a really comprehensive and robust module we're incredibly excited about. All of the new functionality that's coming out with it as well as the functionality that we continually use to enhance and I encourage you with any questions to of course reach out to us. We want to hear your feedback. The majority of our enhancements are client driven and I hope this was helpful. So now we'll shift it over to Kylie. And Kylie, what are your thoughts and how this fits in with the Orion Advantage stack? Now to discuss how you can actually take advantage of and subscribe to the compliance oversight tool. So for those of you who attended our recent Ascent conference or have seen our recent media coverage, you know that we've recently launched Orion Stacks. And really Orion Stacks came about because as we've acquired and integrated new technologies and capabilities into our ecosystem. We've been able to upgrade our product packages to allow you to subscribe to our products collectively and at a consolidated price that represents a discount over purchasing all of our products separately. We call these our stacks and importantly for features like compliance oversight that is Lewis explained, really represent the best of what we have in terms of bringing together all of our technology capabilities. You can take advantage of our Advantage Stack to be able to bundle in your access and your cost for compliance oversight as part of your overall Orion bundle and overall Orion price. And so we encourage you to reach out to our sales team at stacks at orion.com to learn more and to figure out how. Already right now you can go ahead and elect our Advantage Stack and start taking advantage of the compliance oversight tool as well as many other features that are only available as part of our Advantage Stack. All right. So now we're going to turn it over to some Q&A and we do have a few questions that have come in. So I'm going to start with the first one. So great question. How is all of this track from an audit perspective? Louis, you want to take that one? Sure. So this is an excellent question, So. The the whole foundation of Orion compliance again is an end to end workflow solution for compliance, firm and employee oversight. And So what that means is that all of the workflows, all of the meaningful actions, who's doing something, when did they do it, what was the outcome? All of those items are tracked within the system within the respective items. So when it comes time for an audit or just an internal meeting, you can slice and dice that data. Export it on demand and then have that robust audit trail ready for the meeting. Great. Let's see, Okay. Next question, how does the tool consider different share class eligibility in terms of custodians? So this is a great question. So with respect to custodial eligibility, the way the share class tool works is it brings in of course the current fund that you're holding or that your client's holding. It then looks for any potentially cheaper funds and again using a key mix of metrics such as 12B1 fee net and gross expense ratio, sales load. But it also pulls in custodial notes from the fund availability list. So you're able to get a full holistic picture of what's eligible at what custodian, under what condition, perform your due diligence and then go from there. That's great. If I might add to that just a little bit. So I know from speaking to firms, one of the things that trips them up when they're going through an SEC exam, for example, is maybe on the day they purchased the share class, right? Maybe that was the cheapest share class available because, you know, maybe the account size didn't read them, didn't reach the minimums for the custodians. Or maybe the custodians as we know they do over time, we're able to approve and list other share classes over time. Help us understand how the tool would work in those scenarios to give you updated information. Absolutely. So what the system does first is it aims to eliminate noise, right? So when you're when you're reviewing shared classes, it's going to make sure that if you review an item first, it's not going to populate it again the next day until you approach a new review period. But what it does do is it looks at the minimum investment for the currently held fund and then it tells you how many accounts would be eligible to exchange any potentially cheaper funds. The system further than if if required by your policy, allows you to create a rule where you can exclude potentially cheaper options based on the minimum investment. So for example, let's say that your current fund has a minimum investment of 0 and that's the expectation for all current funds. Going forward, you could simply say hey, if there's any potentially cheaper funds that have a higher minimum investment than 0 at this custodian or all custodians, please exclude. That's great. Well, that's really interesting. I think the next question is around the cost. So what is the cost of this and does it cost extra with the advantage stack? Great question. So as I mentioned, our advantage Stack takes the best that we have across all of Orion, including importantly our client oversight tool and it wraps it in for one consolidated price and so. If you are subscribing to the Advantage staff, there is not a separate cost for you. Your firm is able to take advantage of all of the tools we've been talking about today, all of those capabilities and it's all part of your one Orion cost. And I would also say if you're interested in seeing a further demo of it, learning more and also. Being able to see exactly how those costs are going to look for all of your Orion services for your firms, again, please reach out to our sales team. And you can do that by simply emailing them at stacks at orion.com. All right, I think that looks like all of our questions today. Louis, you want to close us out? Sure that. All right. This looks like a wrap. Thanks for taking the time to join us. Again, like Kylie mentioned. Please click the button below to book a demo. Customize demo at your convenience, and we look forward to seeing you on the next one. Thanks everyone. Take care. _1716159468421