from osmoda research · wealth mgmt

24/7 portfolio watch. SEC filings, ready.

Multi-custodian. KEYD vault per custody. Audit-clean. Schwab, Fidelity, Pershing-Wove, Altruist pulled into one unified household view; Marketing Rule policy checker built in; CCO co-pilot writes the §204-2 export and the §206(4)-7 annual review.

Spawn an RIA stack Compliance hub →

TL;DR

• RIA AUM hit $144.6T in 2024, +12.6% YoY; channel CAGR ~11% over the decade [IAA]
• ~37% of RIAs retire in the next decade; consolidators now control $1.5T AUM [Cerulli]
• SEC Marketing Rule Risk Alert Dec 16, 2025 — repeat findings now go to Enforcement [SEC]
• Reg S-P safeguarding: $1.5B+ AUM firms comply by Feb 2, 2026; smaller by Aug 2, 2026 [SEC]
• Addepar ~$65K/yr at $220M AUM (0.03%); Black Diamond $20-60K+; Tamarac from $189/mo
• os.moda: KEYD per custodian, SHA-256 ledger maps to Marketing Rule §206(4)-1 evidence

1. The pain — compliance + a seat-priced wealth stack

RIAs are growing fast — AUM $144.6T, +12.6% in 2024, advisor headcount up 6.7% — but the compliance cost curve is steeper. The SEC Division of Examinations published a Marketing Rule Risk Alert on Dec 16, 2025 flagging testimonials/endorsements disclosure failures, "clear and prominent" placement gaps, and third-party rating payment disclosures — and warned that repeat findings will be referred to Enforcement. Reg S-P safeguarding amendments kick in for $1.5B+ AUM firms on Feb 2, 2026 and for the rest on Aug 2, 2026.

The tech stack is expensive and seat-priced. Addepar runs ~$65K/year at $220M AUM (0.03% basis-point pricing, designed for $500M+ with alts). Black Diamond typically $20-60K+/year at $100-500M AUM. Orion's Foundation Stack is quote-driven plus 0.15% on direct indexing models; Tamarac entry-level is $189/month scaling sharply. Add compliance tooling — COMPLY / RIA in a Box / SmartRIA at $3K-$25K/year — plus a Wealthbox or Salesforce FSC CRM seat tax. A $400M RIA easily clears $100K/year on software before custodian fees.

2026 makes it sharper. Tax-loss harvesting is commoditizing fast — Frec runs direct indexing at 0.09% with $20K minimums; Wealthfront stock-level TLH is free above a $100K threshold — and direct indexing AUM is on track for $800B by 2026. Custodians are repricing: Altruist now serves 5,500+ advisors as a tech-native challenger to Schwab Advisor Center and Fidelity Wealthscape; Pershing Wove targets the same. The CCO who has to file an accurate Form ADV across all of that is using spreadsheets.

Addepar

UHNW + alts-heavy reporting platform, ~0.03% AUM pricing, ~$65K/yr at $220M. Best-in-class for complex book; expensive and overkill if you don't have alts.

Black Diamond (SS&C)

Mid-to-large RIA reporting at $20-60K+/year. Excellent reporting but a reporting tool — workflow and comms still need other vendors.

Orion

Bundled portal+planning+accounting+billing+reporting with 0.15% direct-indexing add-on; quote-driven. Strong, broad, but seat-and-AUM-priced and AI is tier-locked.

Tamarac / Salesforce FSC / Wealthbox

Tamarac from $189/mo scales fast; FSC is enterprise-priced; Wealthbox is lightweight. Each owns one slice; CCO assembles audit by hand.

2. What 2026 is bringing

Marketing Rule Risk Alert Dec 2025. SEC explicitly warns repeat testimonial/endorsement disclosure findings will be referred to Enforcement; 2026 exams are pulling on the thread [SEC; Alston & Bird].
Reg S-P safeguarding compliance. $1.5B+ AUM by Feb 2, 2026; smaller firms by Aug 2, 2026 — written incident response, 30-day breach notification, vendor diligence required.
Direct indexing tracking $800B AUM. Frec at 0.09% (0.04% rebate) and Wealthfront at free-above-$100K are pricing the boutique TLH offering toward zero.
Altruist crossed 5,500 advisors. Fastest-growing custodian in 2025 T3 study — multi-custodian is now the default RIA posture, not the exception.

3. The os.moda stack

1 · naga (KEYD vault per custodian) holds Schwab, Fidelity, Pershing, Altruist, and direct-custodian API keys — each signed action is scoped, logged, and revocable. The LLM never sees a credential.
2 · soot (custodian + portfolio sync) runs daily + intraday + extended-hours pulls from Schwab Advisor Center, Fidelity Wealthscape, Pershing Wove, Altruist; reconciles cost basis, corporate actions, dividend accruals; flags exceptions.
3 · frog (portfolio monitoring + TLH) runs drift bands, household-level rebalancing, TLH scans across the household — including the direct-indexing sleeve. Generates trade lists per custodian, ready for advisor approval.
4 · tofu (client comms + branded portal) runs the white-label portal (web + Telegram/WhatsApp), answers routine "what's my balance/what changed today", escalates to the advisor on anything advice-shaped. Voice channel for after-hours alerts.
5 · lantern (Marketing Rule + Form ADV) ingests advertising drafts (web copy, LinkedIn, decks, performance one-pagers), tests against §206(4)-1, generates the §204-2 books-and-records package, assembles Form ADV updates from operational state.
6 · naga (Reg S-P + cybersecurity) enforces the safeguarding policy: vendor diligence files, incident response playbook, 30-day notification draft template, audit ledger that proves you ran the controls.
7 · haku (CCO co-pilot) drafts the annual Code of Ethics attestations, gift-and-entertainment logs, personal trading pre-clearance, year-end §206(4)-7 compliance review.

4. Why it works

Sovereignty + compliance

KEYD vault means each custodian key is scoped to signed actions only; SHA-256 hash-chained ledger maps directly to §204-2 books-and-records requirements and the §206(4)-1 advertising substantiation file the SEC Marketing Rule expects. EU residency (Frankfurt EU-1) is available for cross-border families and EU-domiciled feeders.

Workflow integrity

Watchdog 6s median wedge recovery means a market-open price spike doesn't break your TLH scan. NixOS atomic rollback lets you revert a custodian adapter the moment Schwab changes a field. Persistent agent memory means the CCO co-pilot remembers your firm's actual policies, not generic SEC boilerplate.

Economics

$29-$299/month flat replaces $80K-$200K/year of stitched Addepar + Black Diamond + COMPLY + Wealthbox + portal vendor + extended-hours alerting. BYO LLM key means per-client AI cost doesn't compound with AUM. Apache-2.0 means if we go away, your operations don't.

5. The 3–5 year future

2027 · agentic portfolio management with hard-codified risk policy. Frog runs household-level rebalancing inside naga-enforced risk bands the advisor codifies once. The advisor sets the policy; the agent runs the book — RIA capacity per advisor doubles without a junior PM hire.
2028 · the client's RIA agent. Each household gets a private agent on your box that knows their plan, custodian holdings, cash flows, stated risk tolerance — answers "can I afford this?" in real time over Telegram/WhatsApp/voice, escalating to the advisor on anything that moves the plan.
2029–2030 · blockchain-attested custody + real-time SEC filings. Custodian holdings cryptographically attested at the share-lot level; Form ADV-PF, Reg S-P incidents, and Marketing Rule artifacts file from the same signed-action ledger. The annual §206(4)-7 review becomes a continuous attestation.

FAQ

How does this satisfy the SEC Marketing Rule and the Dec 2025 Risk Alert?

Lantern reviews every piece of advertising — testimonials, endorsements, third-party ratings, hypothetical performance — against §206(4)-1 before it ships, requires disclosures be "clear and prominent" at the testimonial location, and logs the substantiation file. When the examiner asks for your books-and-records under §204-2, you export the bundle.

Can it handle a multi-custodian book — Schwab, Fidelity, Pershing, Altruist?

Yes. KEYD holds one scoped credential per custodian; soot runs published-API adapters for each; frog reconciles positions and cost basis across the household. Extended-hours alerts are scheduled crons that the watchdog will revive if they wedge.

Does this replace Addepar or Black Diamond?

For most $100M-$2B RIAs without heavy alts, yes — portfolio reporting, billing, and the client portal are spirits, not a separate vendor. If you have a UHNW book with complex alternative-investment lookthroughs, run Addepar alongside; soot pulls its data into the unified ledger.

A CCO can sleep through earnings season. So can the advisor.

Spawn an RIA stack →

1. The pain — compliance + a seat-priced wealth stack

Addepar

UHNW + alts-heavy reporting platform, ~0.03% AUM pricing, ~$65K/yr at $220M. Best-in-class for complex book; expensive and overkill if you don't have alts.

Black Diamond (SS&C)

Mid-to-large RIA reporting at $20-60K+/year. Excellent reporting but a reporting tool — workflow and comms still need other vendors.

Orion

Bundled portal+planning+accounting+billing+reporting with 0.15% direct-indexing add-on; quote-driven. Strong, broad, but seat-and-AUM-priced and AI is tier-locked.

Tamarac / Salesforce FSC / Wealthbox

Tamarac from $189/mo scales fast; FSC is enterprise-priced; Wealthbox is lightweight. Each owns one slice; CCO assembles audit by hand.

2. What 2026 is bringing

Marketing Rule Risk Alert Dec 2025. SEC explicitly warns repeat testimonial/endorsement disclosure findings will be referred to Enforcement; 2026 exams are pulling on the thread [SEC; Alston & Bird].

Reg S-P safeguarding compliance. $1.5B+ AUM by Feb 2, 2026; smaller firms by Aug 2, 2026 — written incident response, 30-day breach notification, vendor diligence required.

Direct indexing tracking $800B AUM. Frec at 0.09% (0.04% rebate) and Wealthfront at free-above-$100K are pricing the boutique TLH offering toward zero.

Altruist crossed 5,500 advisors. Fastest-growing custodian in 2025 T3 study — multi-custodian is now the default RIA posture, not the exception.

3. The os.moda stack

1 · naga (KEYD vault per custodian) holds Schwab, Fidelity, Pershing, Altruist, and direct-custodian API keys — each signed action is scoped, logged, and revocable. The LLM never sees a credential.

2 · soot (custodian + portfolio sync) runs daily + intraday + extended-hours pulls from Schwab Advisor Center, Fidelity Wealthscape, Pershing Wove, Altruist; reconciles cost basis, corporate actions, dividend accruals; flags exceptions.

3 · frog (portfolio monitoring + TLH) runs drift bands, household-level rebalancing, TLH scans across the household — including the direct-indexing sleeve. Generates trade lists per custodian, ready for advisor approval.

4 · tofu (client comms + branded portal) runs the white-label portal (web + Telegram/WhatsApp), answers routine "what's my balance/what changed today", escalates to the advisor on anything advice-shaped. Voice channel for after-hours alerts.

5 · lantern (Marketing Rule + Form ADV) ingests advertising drafts (web copy, LinkedIn, decks, performance one-pagers), tests against §206(4)-1, generates the §204-2 books-and-records package, assembles Form ADV updates from operational state.

6 · naga (Reg S-P + cybersecurity) enforces the safeguarding policy: vendor diligence files, incident response playbook, 30-day notification draft template, audit ledger that proves you ran the controls.

7 · haku (CCO co-pilot) drafts the annual Code of Ethics attestations, gift-and-entertainment logs, personal trading pre-clearance, year-end §206(4)-7 compliance review.

4. Why it works

Sovereignty + compliance

Workflow integrity

Economics

5. The 3–5 year future

2027 · agentic portfolio management with hard-codified risk policy. Frog runs household-level rebalancing inside naga-enforced risk bands the advisor codifies once. The advisor sets the policy; the agent runs the book — RIA capacity per advisor doubles without a junior PM hire.

2028 · the client's RIA agent. Each household gets a private agent on your box that knows their plan, custodian holdings, cash flows, stated risk tolerance — answers "can I afford this?" in real time over Telegram/WhatsApp/voice, escalating to the advisor on anything that moves the plan.

2029–2030 · blockchain-attested custody + real-time SEC filings. Custodian holdings cryptographically attested at the share-lot level; Form ADV-PF, Reg S-P incidents, and Marketing Rule artifacts file from the same signed-action ledger. The annual §206(4)-7 review becomes a continuous attestation.

FAQ