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What background checks and professional screening are performed on multifamily office staff?

Short answer

A multifamily office may verify identity, employment history, education, references, and role-related credentials. For personnel associated with registered investment advisers, SEC Investment Adviser Public Disclosure records may provide registration, employment, and disciplinary information. FINRA BrokerCheck provides public information about covered financial professionals. When an employer obtains a consumer report for employment purposes, the Fair Credit Reporting Act includes disclosure, authorization, and adverse-action requirements. [INSIGHT-1] [INSIGHT-2] [INSIGHT-3] [INSIGHT-4]

Employment screening

Employers may use background information to evaluate applicants for employment. The Federal Trade Commission identifies employment, education, criminal, credit, and other consumer-report information as possible parts of an employment background check. The checks used should relate to the position and comply with applicable law. [INSIGHT-3] [INSIGHT-4]

A multifamily office can document which checks apply to each role, such as identity, employment, education, references, or professional credentials. The sources cited here do not establish one universal screening package for every multifamily office role.

Regulatory and professional records

The SEC’s Investment Adviser Public Disclosure system provides public information about investment adviser firms and representatives, including registration and reported disciplinary information. [INSIGHT-1]

FINRA BrokerCheck provides public information about many financial professionals and firms, including registration, employment history, qualifications, disclosures, and regulatory events. [INSIGHT-2]

These databases apply to the professionals and records covered by the respective systems. They do not replace identity, employment, education, or reference checks.

Make sure anyone you meet, you do full due diligence with, walk their manufacturing floor, get to know them, do the full due diligence, background checks, even if they're a verified member.

Richard C. Wilson, Family Office ClubRichard C. Wilson, Overview of the $100M Summit: Most common points, trends, unique strategies

Federal requirements when using consumer reports

The Federal Trade Commission states that an employer using a consumer report for employment purposes must provide a stand-alone written disclosure and obtain the applicant’s written permission. If the employer may take adverse action based on the report, the employer must provide a copy of the report and a summary of rights before the action, then provide required notice after the decision. [INSIGHT-3] [INSIGHT-4]

Additional state or local requirements may apply. The sources cited here do not establish a general requirement for periodic rescreening after hire.

Sources

  1. SEC Investor.gov, Investment Adviser Public Disclosure
  2. FINRA BrokerCheck

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