Managing Conflict

Dover Consulting Group is a division of Dover Partners Inc., an independently owned  investment management firm. We are not affiliated with any other financial services company and have no products to sell, other than our expertise. Virtually all of our revenues come from client fees.  To avoid possible conflicts, we don’t consult to financial services companies that sell products to our clients. But it’s possible that some of our business practices might be construed as conflicts of interest.  So we’ve thought hard about any possible conflicts, and have disclosed them in the following sections:

Possible Conflicts

This information supplements Dover’s Form ADV Part 2 (PDF). Please review this page in conjunction with our Form ADV Part 2.

In reviewing our business practices to identify possible conflicts of interest, we considered:

– Relationships involving Dover that could, in the reasonable opinion of a prudent person familiar with the circumstances, represent a conflict of interest;

– Soft dollar arrangements with any broker dealer, research organization, or any like organization.

Management Services

Dover Consulting, through another division, provides investment management services. However, consultants never recommend Dover’s management services to consulting clients. Nor do we recommend consulting services to our management clients.

Revenue Neutral

As a fiduciary, we want to avoid pushing any particular product. For this reason, we remain revenue neutral: we charge a set fee and pass revenue shares back to the client (known as the Frost Model of revenue sharing). The revenue we generate will not vary. Exceptions to this rule of remaining revenue neutral may be granted in the case of special client requests or negotiations.

Proprietary Websites

Custodians/broker dealers and mutual fund companies maintain proprietary websites for investment advisory firms (such as Dover). These websites provide information necessary to facilitate the relationship between the investment provider and the investment advisory firm, such as descriptions of procedures, administrative forms, lists of securities offered, etc. Additionally, these websites include useful practice management information, such as articles on SEC compliance, best practices and marketing suggestions.

To the best of our knowledge, Dover does not receive access to proprietary websites that are not generally offered to other similar advisory firms.

Newsletters/Research Papers

Dover receives newsletters and research papers from custodians/broker dealers and mutual fund companies. These organizations send newsletters and research papers to investment advisory firms (like Dover). The newsletters and research papers cover a variety of topics, such as SEC compliance, investment theory, industry updates, product information, best practices, etc. To the best of our knowledge, Dover does not receive newsletters or research papers that are not generally offered to other similar advisory firms.

Conferences/Seminars (Events)

Custodians/broker dealers and mutual fund companies regularly offer conferences or seminars (events) to discuss issues of interest to investment advisory firms (such as Dover). Dover does not currently send representatives to these events.  However, we could choose to do so in the future. Certain events are offered at no charge, others charge attendance fees, and some have attendance fees but waive those fees for Dover representatives.

To the best of our knowledge, Dover does not receive any event invitations or offers of fee waivers that are not generally offered to other similar advisory firms.

How does Dover protect client privacy?

To the greatest extent possible, Dover seeks to keep confidential client data private, unless our clients request that we share information. In accordance with the 1999 Financial Services Modernization Act (popularly known as Gramm-Leach-Bliley), we have developed a formal Privacy Policy. The policy proscribes our sharing of client information with any person or entity.  We do not share customer information with any other entity, except as required by law.