Is There Any Sizzle in the Alternative Asset Custody Sausage? Kirk Chisholm, Part 1

“My other piece of advice, Copperfield,” said Mr. Micawber, “Annual income twenty pounds, annual expenditure nineteen to nineteen six. Result happiness. Annual income twenty pounds, annual expenditure twenty pounds and six. Result misery.”

David Copperfield (1850)

Intro:

Kelly Coughlin is CEO of BankBosun, a management consulting firm helping bank C Level Officers navigate risk and discover reward. He is the host of the syndicated audio podcast, BankBosun.com. Kelly brings over 25 years of experience with companies like PWC, Lloyds Bank, and Merrill Lynch. On the podcast, Kelly interviews key executives in the banking ecosystem to provide bank C-Suite officers risk management, technology, and investment ideas and solutions to help them navigate risks and discover reward. And now your host, Kelly Coughlin.

Kelly Coughlin:

Greetings. This is Kelly Coughlin, CEO of Bank Bosun, helping bank C-Suite execs navigate risk and discover reward in a sea of threats and opportunities. I've been in the financial services industry since I was 23 years old. That was a long time ago. Merrill Lynch, PWC, Lloyds Bank, Global Bridge. I've seen a lot of different products, services, strategies, and tactics, and other than during the periods where the industry blows it through errors, omissions, and to a certain extent, unrestrained greed, it truly is a terrific industry. One of the most interesting segments of the industry is the alternative investments area. The opportunities to invest in alternative investments has never been greater. Alternative investments can range from professionally managed venture capital investments and hedge funds to private LLC investments in a local real estate deal. Along with this huge increase in investment choices comes the ability for individual retirement accounts to make these investments.

It used to be that IRAs could only invest in fairly plain, vanilla securities like registered investment companies, mutual funds, ETFs, and individual stocks and bonds. Now, IRAs can invest in just about any asset, but unlike an individual’s traditional, say a cash account where an investor can buy the asset and hold the evidence of the purchase of that asset whether it be an LLC agreement or a stock certificate in any place he or she wishes, in IRAs, you can only invest through an improved IRA trustee custodian.

You can't just buy it yourself and hold it in your safe deposit box or file cabinet. You can only buy it through one of these approved IRA trustee custodians. In this world, you have two categories of approved trustee custodians. Bank custodians and non-bank custodians. I think the assumption is that all banks with banking powers are approved to hold IRA assets so they don’t need any special authorities.

The other IRA trustee custodians are the non-bank custodian. The IRS maintains a list of a financial institution’s need to demonstrate some level of financial internal controls in order for them to get approved. Currently, there are about 75 financial institutions on that list. As I look at the list, it seems most of them are broker-dealer type organizations. The subject of this podcast is on the IRA trustee custodian business. Why? Recall, I said alternative investments are one of the most interesting segments of the financial services industry. IRA trustee custody is probably one of the most dull and uninteresting segments of the business.

A famous marketing guy, I think it was Elmer Wheeler from upstate New York, a sales guru in the mid-1900s said, sell the sizzle, not the sausage. I'm here to tell you that there ain't much sizzle in the IRA custody business. While I think Napoleon said, man should not know how laws and sausage are made, today we're going to learn a little bit about how the sausage is made and why it's important, and what we need to know to evaluate the sausage maker that is the IRA custodian.

With that in mind, I'm going to interview a very, very sharp financial advisor from Lexington, Massachusetts. He's a wealth manager and principal at Innovative Advisory Group. In addition to traditional investing, portfolio management, and wealth management, he is especially strong in the self-directed IRA business and the alternative investment area.

His name is Kirk Chisholm. He's produced an online course titled The Ultimate Insider’s Guide to Self-Directed IRA Custodians and Administrators, and the publication A Quick Start Guide to Self-Directed IRAs. Kirk has turned what some people, including financial institutions like bank IRA custodians and non-bank IRA custodians into a sizzling business line at Innovative Advisory Group. With that in mind, I'm hoping I have Kirk on the line, all the way from Lexington, Massachusetts. Kirk, are you there?

Kirk Chisholm:

I am. How’s it going, Kelly?

Kelly Coughlin:

Great, Kirk. Thanks for attending. I hope you're doing well. Did you hear my intro there, Kirk?

Kirk Chisholm:

I did, yes.

Kelly Coughlin:

Anything you disagree with on that?

Kirk Chisholm:

No. I thought it a very descriptive intro, yeah.

Kelly Coughlin:

Okay. Great. I'm really looking forward to talking to you. You're obviously a sharp and capable guy in this space, and you're a recognized expert. You were recognized as one of the top financial advisors in the country. Tell us about this. Was that at USA Today? Or where was that?

Kirk Chisholm:

Yeah. Thanks. That was a recent accolade I received. It was very unexpected, and it was very nice to be acknowledged. Investopedia had a list of the top 100 most influential financial advisors, and I was ranked number seven. I have to say, I was surprised to be up there. There were a lot of great people who are in the top 10, and I know many of them and they've all done a great job. I'm humbled to be among such a great group.

Kelly Coughlin:

Excellent. That's great. Let's get right into it. You know what we're going to talk about here. You focused a bit of your career on IRA custody and trustee business. Why has that been such a point of interest and focus for you?

Kirk Chisholm:

I'll tell you a little story. It's interesting. A number of years back, I was working for the wire house channel at Smith Barney. One of my longtime clients came to me and said, I want to invest in this private mortgage. I said, great. That's awesome. He said, I'd love to do it with my IRA. You can do that? He went on to tell me, apparently, somebody had educated him about it. I started reading up on it and realized, wow, this is fantastic. I don’t have to limit my clients’ IRA funds to stocks, bonds, and mutual funds. There is a virtually unlimited amount of investments out there, and to limit yourself doesn't seem like the best option. I went and talked to my manager and said, my client wants to do this. Can we do it? He said, no. You can't do that. I said, no, actually you can do it, and I went on to explain to him how you can do it and how it works. He said, well, you're right. You can, but we can't.

Then, the lightbulb went off. My client was a longtime client. He's a good friend of mine. I wasn't getting paid for it, but I helped him through the process. I went and took the next three months to research the process, and this was back before the Internet was a big deal. There was information out there, but it wasn't a lot. It took me a while to do this research. I was trying to do it right. I wanted to make sure he didn't get himself into trouble. Came to the conclusion that this was such a great opportunity for investors, and nobody knows about it. Spent the next six months researching custodians and administrators and trying to learn the inside and out of each of these companies, and it took me a long time to do this research. Really spent the next few years trying to figure out how I can work with my clients on this, because I saw so many interesting opportunities outside of the stock market that I really wanted to try to take advantage of that.

My partner and I started our current firm, and really the point of it was to focus on providing advice to alternative investments inside of self-directed IRAs. So, while we do traditional wealth management services like tens of thousands of other financial advisors out there, we also offer this specialty, which very few people understand. I think there are currently, there's about 4 or 5% of IRA holders are holding alternative assets. There's very few of them that are actually doing that. Out of the IRA holders, let's say maybe no more than 10% are even aware that this can be done.

Most people don’t even know. It's too bad, because some people have some really interesting investment strategies just for their personal taxable money, and if they were to use their retirement funds, they would have a lot more opportunities available to them, especially when many of them don’t contribute to their retirement funds because they don’t want that money to go into things they don’t understand. They want it to go into investments that they do understand.

 

An interesting story. When I was, I think, about a year in, I had started at Paine Webber back when they were Paine Webber. About a year in, I had spoke to this individual who owns real estate. I was talking to him about how he ought to diversify into other investments. He said, look, all money goes into real estate. Every nickel I have goes into real estate. Why would I ever invest into stocks, bonds, and mutual funds? I know real estate. I don’t know stocks. Why would I ever do that? I said, I can't argue with you. If you're doing well with real estate and that's your expertise, you should definitely not invest in things you don’t know. At the time, I wasn't aware of this, but real estate happens to be the most common asset held in self-directed IRAs. There are a number of people who are actively using this asset, but in general, most people are not aware of this type of investment strategy.

Kelly Coughlin:

They can't buy the actual asset itself. They can buy an LLC, C-Corp, that sort of thing, that holds real estate. Probably not a sub-S. They can't buy the asset directly, correct?

Kirk Chisholm:

Well, they can, actually. People always ask, what can you invest in? It's probably easier to say what you cannot invest in, because what you can invest in is virtually unlimited. What you cannot invest in is what is described in the Internal Revenue code pretty explicitly is, you cannot invest in collectables. You cannot invest in life insurance on yourself, and you cannot invest in S-Corps. There are some other nuances there, but more or less, those are some things you cannot invest in. There are exceptions to those, but more or less, the S-Corps, you're correct. But you can own real estate inside of an IRA. That is the most common asset held in IRAs that are alternative, is real estate or real estate-related investments. Many people own it directly. You can own it inside of an LLC or a C-Corp, which some people choose to do, but there's no limitations. It's up the individual to make that decision. The rules for the IRA, the IRA was established in 1974.

Kelly Coughlin:

Oh, ’74? That early?

Kirk Chisholm:

Yeah, with ERISA. Since then, the rules haven’t changed. They've changed a little bit, but this was always allowed. Even back then, you were allowed to invest in all of these different things. It's become an industry. The financial service industry has done a great job bit of marketing to people and convincing people that you have to index, you have to invest in mutual funds, you have to invest in stocks, because that's how they make their money. You can't blame them for that kind of marketing, but that's all people see. There's no contrary marketing that you should be doing something else. People don’t see that, so they have the message that this is what you should be doing. For some people, maybe that's the best choice, but it's not the best choice for everybody.

I think the more people that are aware of this option, the more they'll be able to take advantage of their own expertise in certain areas. Side anecdote, which is kind of interesting. The collectables part. People ask, why collectables? They're an investment for some people, which is certainly true, and there are some collectables which are allowed. I wouldn't say collectables. There are exceptions, but certain coins are allowed within IRAs. Interestingly enough, the reason they put collectables in there was because, at the time they're writing the law, some stolen Nazi art has surfaced. They were afraid that if somebody ever put this stolen Nazi art in an IRA, nobody would ever be able to get it. They had that exception there. They said, you can't put collectables in there, because they were afraid they would never be able to get it again.

Kelly Coughlin:

That's really fascinating. You're saying, back in the ‘70s and ‘80s, you could buy these alternative assets in your IRA?

Kirk Chisholm:

Yes, yes. Some of these companies were started back then.

Kelly Coughlin:

I'm really surprised by that. I thought that this was more of a recent thing. Let me ask you this. It seems as if many of the custodians, especially the brokers who are interested in straight-through-processing on transactions, low-touch, high-volume transactions, they didn't want to have anything to do with these alternative deals. Is that a fair statement?

Kirk Chisholm:

The best way I would describe is this. If you're running a company, you want scale. You want to lower your expenses as much as possible and try to get as much scale as possible. These financial service companies have done a great job at that. The ETF world has taken what Vanguard started as indexing mutual funds and have lowered the expenses even more. The ETF world is erased to zero with expense ratios, but the industry itself has done a great job at scaling. When you're investing in securities, it's easy to scale. When you're investing in rental property and tax liens and horses, you can't scale that. If you wanted to invest in a horse in your IRA at one of these big discount firms, if your account is large enough, it's possible they might let you, but you probably wouldn't want to use them, because if they're specializing in stocks, bonds, and mutual funds, that's the place you want to go.

If they have no idea what they're doing about investing in horses with an IRA, then that's not the firm you want to use to custody your IRA. Ultimately, there's a lot of back office paperwork that has to be done on their part. If they're not familiar with that process, then you don’t want them to mess it up. This is your retirement. The last you want is your retirement to get disqualified and you have to pay taxes on it. You don’t want to focus on companies just because you have your other accounts there. You want to focus on companies that have the best combinations for the investment strategy you're trying to pursue.

Kelly Coughlin:

Do the traditional bank and broker custodians accommodate this type of security willingly or begrudgingly? If they accommodate it.

Kirk Chisholm:

In general, they don’t accommodate it because they don’t understand it, and most likely you're talking to a customer service rep who has no idea. Your most common answer when you ask them to invest in a horse in your IRA is, you can't do that, because they just don’t know. They're not taught that this is an option. Now, if you have a big enough account, maybe you find somebody who is knowledgeable enough. They might say, yes. It can be done. I'm not sure if we can do it. I had a friend of mine who worked at one of the major broker-dealer firms. He had a big client. The client wanted to invest in an alternative asset. He went back, and big enough client, he's trying to make him happy. He went back and said, yeah, we can do that. The back office said, yeah, we'll take care of it.

It literally took the next six months for them to come back and say, sorry, we can't do it. They tried. They tried to figure out. They couldn't figure it out. They finally said, no, we can't do it. They just don’t want that business. It's not scalable. They don’t make big money off of it. it's not just worth the time. They have to hire other people. It's completely understandable why they don’t want it. Recently, some of the custodians that have specialized in this area have been reaching out to these firms and have been working with them and providing sub-custody services. Some of these bigger discount broker-dealers can offer a sub-custody agreement, but are not advertising it, because it's not their main core business.

Kelly Coughlin:

In that sub-custody arrangement, is it fairly typical for the end investor to get one statement from the primary custodian and that sub-custodian asset rolls up into that? Or will they get two separate statements?

Kirk Chisholm:

It depends. Different firms have different arrangements. Some firms will just refer the business to the other firm. Some firms will keep it in-house. One of the more well-known names, after the financial crisis, they pretty much said, we don’t want any alternative assets, which of course gets rid of all the hedge funds that were being held at their firm. Typically, what they would do is charge them a flat fee per year, per asset, and then they would put it as a book entry on their statement. Then, after the financial crisis, they said, we don’t want this business and just told everybody to take a hike.

Eventually, they said, all right. We'll take it back. I think with those firms, they don’t really understand that business, and they don’t want to deal with it. It's kind of a headache for them. I completely understand. I can't blame them. If I was them, I wouldn't want to do it, either. It's not a scalable business. It's a very different business model. I think in general, they don’t want that kind of a business, but now they do accept it more, because it is money. I still don’t think they're going to advertise a lot, because they don’t want to take away from their core money making business.

Kelly Coughlin:

Do you think it's a profitable business line for them? Or is it more or less a breakeven? If they can collect even fees to pay for the additional staff and, I don't know if there's any systems that are required? You think it's more or less a breakeven?

Kirk Chisholm:

I can't speak to whether it's breakeven or not. I think each firm has their own P&L. I wouldn't know specifically, but I would guess that it's probably a break-even or maybe even a loss leader just to keep the business, because they make so much money off the other part of the business. For them to just break even or even lose a little money to keep a client, in general, is probably worth it for them, because they're not doing that much of this business. They're not seeing a ton of it, but if you have an ultra high net worth client who has hedge funds, he's got $20 million at your discount brokerage firm, and he has $2 million in hedge funds, even if they're charging $75, $150 a year, even if you're losing money, it's worth it to you to keep that extra $20 million.

I think in the large part, they see the bigger picture and just say, yeah, we'll do this for cost or close to it. That would be my guess, just based on what I see some of these other specialized firms charge, that most likely that's the case. The other thing, too is, most of these discount brokerage firms that do offer that, I'm not sure that they're offering that inside of IRAs. They're holding hedge funds for book entry on a statement. More times than not, that's actually taxable money. The IRAs, some of them do it. It's become a more recent thing, but they're not really specializing in it.

Kelly Coughlin:

Okay. You mentioned fees, and some of these companies that specialize in it. What kind of fees are you seeing for trustee and custody of alternatives? I assume it's got to be higher than holding $100,000 in mutual funds and ETFs. What kind of fees do you typically see? What's a low end? What's a high end?

Kirk Chisholm:

Fees are an interesting concept. If you're accustomed to a discount broker, you're probably with the recent reduction in many of the firms, you're probably looking at $5 a trade, which is pretty inexpensive to do a trade. These brokerage firms certainly make some money on that, but they also make money on the spreads. They make it different ways. They make it on cash, margin. There's many ways that they can make money. If you're considering a custodian that holds non-traditional assets, they're called a self-directed IRA custodian for short, you'll notice that these are a lot higher. Right now, there's 47 custodian administrators that specialize in this area. There might be a few other stragglers that are out there that don’t advertise, but more or less, that's how many are out there. Out of those firms, every single one of them has more or less a different fee structure.

Kelly Coughlin:

Are you including banks and non-banks? And are you then saying, yeah, there might be more than this, but there's really 47 that are active in this space?

Kirk Chisholm:

There are two different categories. There are custodians, which are typically non-depository bank custodians. Then, there are administrators, which are companies that just do administrative services. You might see them as a TPA and a 401k plan, or administrating insurance, or some other things. There's many uses for administrators, but these have decided to focus on alternative assets inside of IRAs.

It's different from a custodian, but they're required to use a custodian. They might choose to find a local bank and custody of the assets there, and they would do the administrative services of it. Each of these firms, whether internally or some of it's outsourced, they would provide both administration and custody services. Administrators do not provide custody. They outsource it. The custodians provide custody and administrative services, but the administrative services are in-house. It's just a different business model. There are some other differences, but that's the basis of the difference.

Kelly Coughlin:

You say there are 47. How did they get to specialize in this?

Kirk Chisholm:

I actually created—this is such a huge list, and there are so many incorrect lists out there that we actually created a list on our website, because I've seen many lists, and some of them are inaccurate. They have companies on it that aren't even in the space. It's hard. We put together a really comprehensive list. Some of these companies are banks. They are local or regional banks that happen to have a branch or an arm of the bank that does wealth management services and does self-directed IRAs.

Some of these are banks that do offer that. Other firms are exclusively set up to deal with this kind of business. That's all the do, or primarily that's what they do. There are enough people out there that want this service, even though it's only 4% of all IRA holders. It's still a decent amount of people. You're talking about tens of billions of dollars that are in this area within these firms, but each of these firms, they're all different. This is probably the most frequently asked question when people call us up.

They say, what's the best custodian to use? We went through over a year worth of due diligence on all of these firms. We put together extensive resources on them. In the beginning, we thought, well, there will be a handful of best firms, and there are some firms which we prefer over others, but generally speaking, if you look at all these firms, you can't say there's a best firm. Each one of these firms is a little bit different. Their fees are different. Their assets that they allow are different. They're very hard to find a large number of firms that are the same in one area.

Some of the larger firms are more common household names in this area, but generally speaking, real estate, for instance, is the most commonly held alternative in IRAs. Some of these firms don’t offer that. They will not custody real estate for one reason or another. While the Internal Revenue code restricts certain assets, everything else is allowed, but the custodians don’t have to allow it. The custodians can certainly impose more restrictions on what is allowed and not allowed in their own judgement.

For instance, one firm that didn't offer real estate, I asked them a question, obviously. I said, why don’t you offer real estate? You're giving up a big chunk of business. They said, you know what? It's too much of an administrative nightmare for us. We don’t want to deal with it. We'd rather deal with simpler alternatives, and that's what they focused on. They have a decent client base. It's not as if they're hurting for business. They just decided to focus on other areas. There are plenty of alternatives out there that people focus on.

There's one surprising one I'll mention, because I thought it was interesting. I've never come across this with a client, but I've done a little research, and it's interesting. The asset is church bond. One of these companies specializes in church bonds. Many of the companies don’t allow it at all. It's not a big asset class. There actually was a publicly traded closed end fund which converted to a mutual fund later, which was specifically focused on church bonds. There's a market for everything. It's just a matter of finding that market and trying to fill the need.

Kelly Coughlin:

I look at this IRA custody world in three primary categories to evaluate a custodian, and I'm not listing these in order of importance, but fees, features and benefits, and customer service. Is that a reasonable attribution of the categories that you would go through when you look at these 47 players in this industry? How much do you have to pay for it? What do you get for it? And what kind of service do you get from the provider?

Kirk Chisholm:

Yeah. I think that's a good starting point. I categorize them a little bit differently.

Kelly Coughlin:

You're the expert. Tell us how you like to categorize them.

Kirk Chisholm:

We do look at fees. Fees is a very important of the concept, and most investors put that at the top. I don’t, but they do just generally speaking, and I understand it. The fees is definitely an important part of that puzzle. Specialization is another part. As I was mentioning, many of these companies don’t offer all assets. Some of them specialize in certain area. Their most popular asset might be real estate, or it might be Reg-Ds, cryptocurrencies, or whatever it might be, but they have a most common asset or a most popular asset. If you figure it, they're doing a lot of business.

If this is their most common asset, most likely they're going to be good at that asset or good enough. That's another thing we look at is, what are it specializations? We look at customer service. Always a very important part of the puzzle. As you stated, it's much of this is not scalable, so you're dealing with customer service. You're dealing with people that, if you have a rental property, somebody’s getting evicted or you're paying your electric bill.

You need a roof fixed. You may have to converse with these people on a very frequent basis, or you may not. It depends on your investment, but it is important that customer service is knowledgeable. They understand the rules, they understand what you can and cannot do. They will never give you advice. Explicitly tell you they don’t give advice, but they will give you information on what some of the things that you can do or their parameters are.

However, if you have a company that has 100,000 clients and they only have five customer service reps, I'd be pretty confident that you're not going to get great customer service. That's just a shot in the dark, but we look at those metrics and see. Every firm has a ratio of X amount of clients per customer service reps. This firm has only a handful and they've got a lot of clients, I look at that and just say, okay, that's probably not a good sign.

We look at some other things, but that's the customer service piece. We also look at the transaction frequency in reviewing firms. This is not a firm-specific thing, but it's important, and this goes more to the fees in that some custodians have a transactional model, and some have an asset based model. Those are really the two main categories. There are some other different ones. There are some hybrids, but if you have one investment and it's not going to require any effort, you buy it and leave it for 20 years, then you don’t really want an asset based model. You probably want a transaction model, because it’ll end up being cheaper every year.

Kelly Coughlin:

As an account owner, you as a provider would like the asset based fee, right?

Kirk Chisholm:

Well, as a provider, it depends, and this goes to the “…every company’s different.” If you're offering a transactional model, the people that are going to gravitate towards you are people most likely that are in the buy and hold mentality, but if you're in asset based model, then most likely the people that are going to gravitate are the people who are flipping 10 houses in a year, because they don’t have to pay for each transaction. Or if they do, they pay a nominal amount. Investors are going to gravitate to where they're going to get their best bang for the buck.

The custodians and administrators are going to obviously get what the investors gravitate towards. Some of them have multiple fee structures, too. Some offer multiples. We've developed all these resources because the industry is so complicated and convoluted. The discount broker model, everybody’s more or less the same. I think Fidelity recently reduced their $9.99 trade to $5.00, and then their competitors naturally did the same thing, because they're natural competition. With these firms, you don’t tend to get that, because they're not all the same and you have very many different investors. They each have their own piece of the puzzle, but those are the big four that I look at when we're looking at firms. There are many questions we ask, but those are the probably the bigger categories that I would consider.

Kelly Coughlin:

Okay. What sort of feeling of fees would be for that provider? Can you give us any guidance on where that would come in? Certainly, it's more than $100 a year, which is the $100 to $125 typical IRA fee.

Kirk Chisholm:

It depends. I wouldn't make a broad statement with the fees, because the $100 is, I think, probably—I don't know anybody would charge $100 for this service. That's really low. Many of them charge $50, $25 to $100 to even set up the account. In the traditional side, that's what they would charge to bookkeep it, but in this side, it would probably be more expensive. By and large, if you're getting a Cadillac type of service, you're going to have to pay for it. I'll tell you a funny story.

I was talking to a guy recently. He was an attorney. He was telling me about one of his clients. I'll give you some interesting anecdotal story here. There's a side story. The GAO published a report a few years back, I think it was 2014, about IRAs above a certain amount. I believe they went into different categories. This is something you could probably easily find, but I believe there were 300 or 400 individuals who have over $25 million in their IRA, which to me is fascinating, but I've been in this business a while, and it's a rarity to see somebody with $1 million IRA.

I've seen a lot of $700,000-$800,000, but when you get into the millions, you have to be doing a lot of things right, because even if you're maxing out your 401k every year and doing what you should, it's still hard to find people who have that kind of depth in their IRA. To find somebody who has $25-plus is just, it's a really small number. I think there are 314 taxpayers who have an IRA over $25 million. Now, one of them you might know, is our former president candidate Mitt Romney, who had an IRA of, I believe, was $102 million. It was disclosed when he was running, but if you look at the numbers in the GAO study, out of that 314 people, the average of those 314 people is $250 million. If the average is $250 million, it makes you wonder with the biggest one looks like. Now, I've heard a rumor that it's above $1 billion, but certainly, nobody’s going to talk about that in detail. Somebody like that wants some very specific things.

They have a lot of money at stake. They want the Cadillac. They want all that. If they're not getting it from the companies that exist, some of them might just create their own. There comes a point in time where, if it's not there, if you have enough money, why not just create it yourself? Create the solution, because even with all these companies, they do provide some great services, but like I said, there's no one singular best of breed.

There's some great companies, but there's not one solution for everybody is what I mean. If you have that kind of a setup, then there's definitely some room for additional competitors in the market. We've gotten calls from people that wanted to start their own. They've seen our research and they said, hey, we want to see what we can find out about this market. We'd love to start a new company. Technology, as we've seen with gen tech in a traditional space, is a big part of this.

The more that you can scale this part of this business, the more profitable it will be and the better services they'll be able to provide. I think that's the next natural step in this industry, is better technology to provide better services in a cheaper way. From a fees perspective, I think if I was to start one, I would offer multiple fee structures to provide something for everybody so that you can have the transactional as well as assets under management kind of fee structure. I think would be the most flexible. You would appeal to the most investors. Whether that works with your infrastructure is a different question, but that would certainly appeal to everybody.

Kelly Coughlin:

Then, in terms of the features and benefits, certainly specialization is an advantage, but it seems to me that if you were starting one, you would want to be able to specialize in either all of the assets that you could foresee, or those assets representing the top 50, 60, 75%, or some breakdown of where are people putting their money? You need to be able to specialize in those asset classes. Is that a fair statement, do you think?

Kirk Chisholm:

Yeah. It comes to two different parts. You want to offer as much as you can to appeal to the most people, but you don’t want to dilute yourself, either, because obviously, you have people with different expertise and you just have to hire more of them. It doesn't always make sense. When you talk about features and benefits, I call this specialization. I mentioned one firm specializes in church bonds. I think that's great. There is a market out there. Nobody really wants to address it. They did. They specialized in it. I think that's great. Another asset class that people don’t really want to touch is international real estate. There's no reason not to, but people just, the firms just don’t want to deal with the international standards and liabilities and all that. One interesting asset, it's really interesting talking to different firms about this, because nobody really has a firm opinion on it.

Even we've had to research it, because it's not something we'd seen before, but domain names. Investing in domain names inside of an IRA. Many firms look at it as intellectual property. Some firms say, where is the domain being registered? They want to see, what's our recourse? There's so many different levels to these assets. You can't just say, it's an asset. We'll invest. You have to look many levels deep into what are the repercussions if this happens or this happens? I'll give these firms credit. They've put a lot of thought into it. I'd agree with their decision, but they've put a lot of thought into why they will or will not hold these assets.

It makes sense, and if I was them, I would probably have a similar conversation. We have a different view of some assets than they do, but they certainly have full rights to say no for whatever reason that they decide. I think there are a lot of assets on the edge. I think cryptocurrency is another one that people are unsure about for many reasons.

I think a lot of people look at it as a good investment/speculation, I would say. A lot of people are interested, but it's an unknown, so many of these firms won't hold it, because they're not comfortable with it. In another way, they might think it's too risky. Maybe many of it's clients lose money or they get blown up because they don’t know what they're doing. For them, they're just saying it's not worth it for us to custody this asset and have clients lose all their money. It's just for liability reasons or whatever, they just don’t want to do this. There are many reasons that they make these decisions. There are some firms that’ll custody almost anything. There are other firms which actually specialize in only a handful of areas. I think you can look at it from different ways. Our economy has come a long way to the nature of specialization, where many companies used to be generalists, and now, people want specialists. They want somebody who’s an expert in this or an expert in that. There's a market for that, and I think if one firm offers great service to all of these assets, that's fantastic, but I think it's harder to do and you'd have to have the scale to be able to do it well.

Kelly Coughlin:

Kirk, that's all I have right now. That's a very interesting and fascinating topic on the sausage related to IRAs and custody. I think you added some nice sizzle to it, and I appreciate that. I hope our listeners do, too. That's it for part one, but I want to give you an opportunity to tell the listeners how they can get in touch with you if they're so inclined to look for some help from an expert in this industry.

Kirk Chisholm:

Yeah. Thanks a lot, Kelly. We're pretty easy to find. You can go to our website, which is innovativewealth.com, and we have a lot of free resources there that we write up just to educate people about self-directed IRAs and alternative assets. Certainly, you can contact us through that as well.

Kelly Coughlin:

Okay, Kirk thank you very much for your time. I hope you're well.

Kirk Chisholm:

Thanks a lot, Kelly.

We want to thank you for listening to the syndicated audio program, BankBosun.com. The audio content is produced and syndicated by Seth Greene, Market Domination, with the help of Kevin Boyle. Video content is produced by the Guildmaster Studio, Keenan, Bobson Boyle. Voice introduction is me, Karim Kronfli. The program is hosted by Kelly Coughlin. If you like this program, please tell us.  If you don’t please tell us how we can improve it. And now some disclaimers, Kelly is licensed with the Minnesota Board of Accountancy as a certified public accountant. The views expressed here are solely those of Kelly Coughlin and his guest in their private capacity and do not in any way represents the views of any other agent, principal, employee, vendor or supplier.