Designed to fit your
compliance framework.
GOFP is structured as a client-to-recipient transaction. The platform was designed from the ground up to fit within the compliance framework of independent fiduciary advisors. Every key concern is addressed before you deliver a single session.
A three-party structure
designed for compliance.
The recipient is a separate party from the payer. The advisor's fiduciary duty runs entirely to the recipient, not the client who paid. This structure is the foundation of GOFP's compliance architecture.
The three-party structure is intentional. By keeping the payer, the platform, and the advisor as distinct roles, GOFP avoids the custody and conflict-of-interest issues that could arise from simpler arrangements. The advisor never holds client funds. The giver never receives information about the session. The recipient's interests are protected throughout.
Every compliance question
addressed in the platform.
Duty shifts entirely to the recipient
The moment the session begins, the advisor's fiduciary duty runs to the recipient, not the paying client. The advice must be in the recipient's best interest regardless of what the giver might want or expect. GOFP builds a giver acknowledgment into checkout that sets this expectation explicitly before any session is booked.
Confidentiality wall between giver and session
The paying client receives no information about the session. Not whether the recipient showed up, not what was discussed, not what was recommended. This is a hard wall required under Reg S-P. The expectation is set in writing before checkout and documented in the giver acknowledgment. The advisor never has to enforce it manually.
Limited-scope agreement built into redemption
Recipients sign a limited-scope engagement agreement digitally as part of the redemption flow, before any session is booked. The agreement defines the scope of the engagement, clarifies that a third party paid for the session, and confirms the recipient's consent. No separate paperwork is required from the advisor.
FINRA Rule 3220 does not apply to RIAs
FINRA Rule 3220, which governs gifts between broker-dealer associated persons and customers, does not apply to independent RIAs. GOFP is designed for RIAs operating under the Investment Advisers Act, where gifted sessions are addressed through existing fiduciary obligations and internal codes of ethics. No FINRA gift rule analysis is required for most independent advisory practices.
Clean fee structure, no solicitor arrangement
The client purchases a service directly from the advisor on behalf of a third party. GOFP charges a platform fee on each transaction. There is no revenue sharing, no referral fee, and no solicitor arrangement that would trigger additional disclosure obligations. The compensation structure is straightforward and consistent with standard fee-only advisory practices.
Session documentation for your compliance file
Each session is logged as a limited-scope consultation. GOFP generates a session record that the advisor can retain in their compliance file, including the signed engagement agreement, the pre-session brief, and the session recap. All documentation is available for download through the advisor dashboard.
A practical checklist
for your compliance review.
Most independent RIAs will not require material changes to existing procedures to offer gifted sessions through GOFP. The following steps are recommended before your first session.
Review with your compliance officer
Share this page and the GOFP platform overview with your compliance officer or outside counsel. Most independent RIA compliance frameworks will accommodate gifted sessions without significant modification.
Confirm your limited-scope engagement template
GOFP provides a standard limited-scope engagement agreement built into the recipient redemption flow. If your practice uses a custom template, your compliance officer can review the GOFP version for compatibility.
Update your ADV if required
If gifted sessions represent a new service type for your practice, your compliance officer may recommend updating your Form ADV Part 2 to describe the service. This is a minor disclosure update in most cases.
Confirm your recordkeeping procedure
Gifted sessions should be filed as limited-scope consultations in your compliance records. GOFP provides downloadable session records for each engagement, including signed agreements and session summaries.
Set expectations with clients who purchase gifts
Before a client purchases a gift, they acknowledge in the GOFP checkout flow that they will receive no information about the session. This expectation is worth reinforcing in your own client communication as well.
Compliance was designed in,
not added on.
GOFP was built by an independent fiduciary advisor who understood the regulatory stakes from day one. Every platform function reflects that foundation.