Hard Asset Reserve
§SPStandards of practice

The standing rules of the Office.

A private-client office is the engagement document plus the standing rules under which the document is written. The standing rules are below: the role line, the four “nots,” the architectural commitments, the disclosure cadence, the conflicts posture, the standing engagement commitment, and the public-record posture under which the engagement is held.

Every commitment below is reproduced in writing in the brief that opens an engagement, on the depository agreement the client’s counsel reviews, and on the Office’s standing acknowledgement of conflicts. None of it is marketing posture. All of it is the standard the engagement is held to.

§01The role line

What the brief proposes; what counsel decides; what the Office coordinates.

The role line is the standing posture of every engagement. The brief proposes operational architecture inside the Office’s competence — the size band, the metals mix, the form (Good Delivery / kilo / coin), the custody facility from the panel, the implementation sequence, and the exit pathway. Those are procurement and operations decisions the Office is qualified to propose.

Legal, tax, and fiduciary decisions belong to the client’s counsel, CPA, and trustee under their respective retainers. Titling, governing-law selection, estate-plan integration, distribution policy, prudent-investor diligence, and tax-treatment decisions sit entirely outside the Office’s scope. The Office does not propose, recommend, or evaluate any of them.

Once the client and the client’s professionals decide, the Office coordinates the operational pathway: depository agreement, account opening, signature authority, procurement, settlement, and the documentation chain.

The brief proposes architecture and operations. Counsel decides legal, tax, and fiduciary substance. The Office coordinates the operational pathway.

The role line, restated
§02The four “nots”

What the Office is not, named explicitly.

Stating what an institution is not is the discipline that makes its scope coherent. The Office’s scope is the T1 physical reserve layer of the balance sheet; the following adjacent roles are explicitly outside that scope.

Not

A registered investment adviser.

The Office is not registered as an investment adviser and does not claim fiduciary status. The Office does not collect financial-profiling information, does not opine on cross-tier portfolio allocation, and does not produce individualized investment advice.

Not

A bullion dealer or retail metals firm.

The Office does not market inventory, does not operate a commissioned phone-room, does not carry numismatic or semi-numismatic product, and is positioned independently of any dealer relationship. Procurement is executed against the brief’s named refiner-and-format specification.

Not

A law firm.

Titling, governing-law selection, depository- agreement review, and estate-plan integration are decisions the client’s counsel makes under counsel’s retainer. The brief proposes; counsel decides.

Not

A tax adviser.

Cost-basis treatment, schedule classification, IRA treatment, RMD strategy, and step-up review are the client’s CPA’s scope. The Office produces the documentation chain the CPA references.

§03Architectural commitments

Eight commitments. Each one is in writing.

The architectural commitments below are the standing position of the Office. Each one is reproduced in writing in every brief, defended in operations, and is verifiable against the documentation chain the engagement produces. Each is also reproduced on Pricing §04 with the cost-to-Office / protection-to-client arithmetic that supports each line.

  1. 01Two transparent line items, named in writing in the brief before any metal is purchased. A competitive metal spread at acquisition and exit (band by format, firmed at the time of transaction) and a vaulting rate at the chosen facility. No third line item.
  2. 02Refiner provenance named on every bar. Procurement runs through direct counterparty relationships with the top-tier Swiss refiners (Argor-Heraeus, MKS PAMP, Valcambi) and the major sovereign mints. No anonymous-format product at the reserve layer.
  3. 03No numismatic or semi-numismatic product by specification. The brief excludes proof, collectible, and graded product from the reserve allocation. The reserve is bullion-grade and refiner-named.
  4. 04Allocated and segregated custody at a named US depository. One of three US-domestic facilities (the Utah-based Precious Metals Vault, IDS, Brinks) named in the brief by name. No pooled-allocation product. No offshore custody.
  5. 05Directly titled in the client’s name (or the client’s named entity). The depository agreement runs between the client and the depository directly. The Office is not a counterparty to the agreement.
  6. 06Written exit posture before the entry. The plan to sell is named in §07 of the brief at the time §02–§06 are approved. Sell-side spread bands published; buyback counterparty pathway named.
  7. 07A complete documentation chain at delivery and at exit. Trade records, depository holdings statement, titling and depository agreements, summary of the depository’s all-risk insurance coverage, quarterly statements, annual review memo, event records on transfer/distribution/death.
  8. 08No celebrity endorsement, no commissioned phone-room, no national paid media for the metals product itself. The economics of the engagement are not cross-subsidized by retail-channel marketing spend.
§04Disclosure cadence

When the Office discloses what.

A standing disclosure cadence prevents surprise. Every category of information the engagement produces has a named delivery moment, a named recipient, and a named document.

WhenWhatTo whom
Pre-engagementPublished spread bands by format; vaulting-rate range; the four “nots”; the architectural commitments.Public site (/pricing, /standards)
Day 5Reviewed brief: situation, allocation considerations, custody, form, titling, implementation, exit, open questions.Client; readable by counsel/CPA/trustee.
Pre-purchaseSpecific spread firmed at transaction time; depository agreement; titling memo; insurance summary.Client; counsel review prior to execution.
QuarterlyDepository holdings statement (allocated detail); brief written touchpoint from the Office.Client; advisor team on request.
AnnualAnnual review memo — band, custody/titling/exit posture, structural counterparty-chain notes.Client; advisor team.
On eventSale, transfer-in-kind, distribution, death-of-owner records; date-of-death valuation memo where applicable.Client / successor-trustee / CPA.

The full operational treatment of the documentation chain lives on the Custody page. The year-one cadence is on Engagement Timeline.

§05Conflicts posture

The economics are the client’s direct economics.

A conflict is a structural fact, not a moral category. The Office’s posture is to remove the conflicts that would distort the engagement document and acknowledge plainly the conflicts that remain.

Removed by structure

  • ·No commissioned salespeople. The brief is written and reviewed by a founding partner.
  • ·No referral fees paid to the client’s advisors. No revenue-sharing arrangements with counsel, CPA, or trustee.
  • ·No advertising-cost recovery in pricing. The published spread bands are not subsidized by retail-channel marketing spend.
  • ·No AUM percentage. No performance fee. No incentive to grow the held position past the brief’s named band.
  • ·No incentive to delay exit. Exit-side spread is a published band; the Office’s economics are no different at sale than at acquisition.

Acknowledged plainly

  • ·The Office earns a competitive metal spread at acquisition. The number is named in writing before purchase.
  • ·The vaulting rate is negotiated at company level and passed through to the client without markup. Specific rate named in the brief; client retains the depository’s standard receipt directly.
  • ·The Office’s standing relationships with refiners and depositories are commercial relationships. They are disclosed at the engagement opening; they do not generate referral fees back to the Office; they are reviewed annually for material change.
§06Standing engagement commitment

The client’s side of the margin, in writing.

The Office is not a registered investment adviser, not a fiduciary, and does not claim fiduciary status. The standing engagement commitment below is operational, not legal — it describes how the Office runs engagements, defended by the architecture in §03, the disclosure cadence in §04, and the conflicts posture in §05.

The Office runs engagements on the client’s side of the margin. Two transparent line items in writing in the brief before any metal is purchased; the vaulting rate passed through to the client without markup; the named-counterparty exit pathway; the complete documentation chain. The commitment is operational and verifiable against the engagement’s records.

Standing engagement language
§07Public-record posture

The standard is enforced by what is in writing.

The Office’s public surfaces — this site, the Pricing page’s spread bands by format, the brief composite at /sample-brief/read, the Standards of Practice document, and the four operational diligence pages (/custody, /titling, /exit-architecture, /engagement-timeline) — are intentionally durable references. They exist so that a client’s counsel, CPA, or trustee can verify the engagement’s commitments independently of any conversation.

Public enforcement records in the adjacent retail Gold-IRA segment have been named by the agencies themselves and are referenced on /etf-vs-physical, /pricing §05, and /comparison §03. They are part of the public record and inform the Office’s decision to occupy the inverse architectural lane.

A standard a counterparty cannot verify is not a standard. Every commitment on this page is verifiable against the engagement’s documentation chain.

The verifiability principle
§08Close

The standard is the engagement.

Every commitment on this page is reproduced in writing in the brief, supported by the documentation chain the engagement produces, and verifiable against the Office’s public record. Read it alongside the brief; read it before the brief; read it independently of the brief. The standard is the same in all three cases.