Shearman, Ralston is a dual-registered firm based in Greenwich, CT, that holds a 81.2/100 Fidelon TransparencyScore (13th percentile among state-registered advisers), with 4 registered advisors. Score based on public SEC and FINRA filings.
Shearman, Ralston
Shearman, Ralston INC. · CRD #7320
A dual-registered firm offering both advisory and brokerage services with a clean record.
Fidelon Fact Sheet
Shearman, Ralston INC. is an investment adviser and broker-dealer in Greenwich, CT. It has 4 registered advisors. It manages $97.7 million across 42 client accounts. It charges a yearly percentage of your account that gets smaller as the account grows. When it gives advice, it must put your interests first. When it sells products, it only has to pick ones that are suitable for you. Its services include financial planning. It reports that it can hold or access client money, which the SEC requires firms to disclose. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
13,841st of 15,825
state-registered advisers
Bottom 13%
250th of 282
state-registered advisers in CT
Bottom 11%
25th of 25
state-registered advisers in Greenwich, CT
Bottom 1%
How This Firm Works
Registration & Standard of Care
Dual-Registered — this firm operates as both an investment adviser (fiduciary) and a broker-dealer. Some services come with fiduciary protection, while brokerage services may involve commissions.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Representatives can earn commissions on product sales
What you’d pay
Blended across 1 tiers, from $500,000 - $2,000,000.
This fee is negotiable
“Our advisory fee is negotiable, depending on individual client circumstances.”
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Mutual funds and exchange traded funds fees (management fee and other fund expenses)
- • transaction charges and/or brokerage fees imposed by broker-dealer or custodian
- • commission-based compensation including 12b-1 fees as broker-dealer
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| $0 - $250,000 | 1.50% |
| $250,000 - $500,000 | 1.25% |
| $500,000 - $2,000,000 | 1.00% |
| $2,000,000 - $30,000,000 | 0.75% |
| $30,000,000 and above | 0.50% |
Billed quarterly in arrears, based on the average monthly balance of the billing period
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Registered as investment adviser with fiduciary obligation
- Clean regulatory record — no disclosures, arbitrations, or fines
Things You Should Know
- Also operates as a broker-dealer — may not always be required to put your interests first
- Its brochure says it receives research or services from brokers, but it does not say those perks can shape which broker it picks for you, the firm benefits by not paying for those things, or whether every client benefits or only some. Ask how the firm chooses the broker for your trades and whether perks play any part.Item 12.A.1
- Its brochure names securities commissions or 12b-1 distribution fees from mutual funds as conflicts, but it does not say what the firm is paid for it, explain what this arrangement tempts the firm to do, or say what it can cost you. Ask whether anyone at the firm earns a commission on investments recommended to you, and whether it lowers your fee.Items 10, 11, 12.B and 14
Conflict Audit
Multiple structural conflicts identified in regulatory filings. These are disclosed business arrangements — worth asking about, not disqualifying.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
92/100
Strong
Avg for dual-registered firms: 66.8 | Top 10%: 97.2
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
77/100
Fair
Avg for dual-registered firms: 70.4 | Top 10%: 80.7
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
65/100
Fair
Avg for dual-registered firms: 62.2 | Top 10%: 79.3
Enforcement History
Past actions taken by the SEC, FINRA, or state regulators, and how well the firm supervised its people.
87/100
Strong
Avg for dual-registered firms: 59.6 | Top 10%: 86.5
What their brochure tells you
The firm must give you this brochure, Form ADV Part 2A, before you sign. We read it against the SEC's own instructions, item by item. Quotes are the firm's own words; page numbers refer to the filed brochure. What is in a brochure?
Can you tell what you'd pay and when?Brochure Fee Clarity75/100
The SEC asks every brochure to spell out the fee schedule, whether fees can be negotiated, how and when you are billed, the other costs you pay, and refunds.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
Our fee for portfolio management services is based on a percentage of the assets in your account and is set forth in the following annual fee schedule:p. 5
- Does it say whether the fee can be negotiated?CoveredItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
Our advisory fee is negotiable, depending on individual client circumstances.p. 5
- Does it say whether the fee comes out of your account or gets billed?CoveredItem 5.B
A fee taken straight from your account is easy to stop noticing.
We will deduct our fee directly from your account through the qualified custodian holding your funds and securities.p. 5
- Does it say how often you're charged?CoveredItem 5.B
Monthly, quarterly, in advance or in arrears changes what you owe when you leave.
The annual portfolio management fee is billed and payable, quarterly in arrears, based on the average monthly balance of the billing period.p. 5
- Does it list the other costs you pay, like fund and custodian fees?Not found in the brochureItem 5.C
The advisory fee is rarely the whole bill; fund, trading and custody costs come on top.
What to askAsk what you will pay beyond the advisory fee, in dollars, over a typical year.
- Does it say how you get money back if you leave mid-period?CoveredItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
You will incur a pro rata charge for services rendered prior to the termination of the portfolio management agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client.p. 5
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity54/100
The SEC asks the brochure to name each way the firm gets paid besides your fee, what that tempts the firm to do, and what it can cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
If its people earn commissions on securities, does it explain them?
Securities commissions
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Our firm will receive commission-based compensation, including 12b-1 fees, in connection with the purchase and sale of securities or the holding of securities that issue 12b-1 fees.p. 6
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
This practice presents a conflict of interest because our firm may have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on your needs.p. 6
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether anyone at the firm earns a commission on investments recommended to you, and whether it lowers your fee.
If the firm collects 12b-1 fees from mutual funds, does it explain them?
12b-1 distribution fees from mutual funds
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Our firm will receive commission-based compensation, including 12b-1 fees, in connection with the purchase and sale of securities or the holding of securities that issue 12b-1 fees.p. 6
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether any fund you own pays the firm a 12b-1 fee, and whether a cheaper share class exists.
If it uses an affiliated broker-dealer, does it explain what that means for you?
An affiliated broker-dealer
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Shearman, Ralston Inc. is registered as a securities broker-dealer, and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation.p. 6
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether your trades or products go through a company the firm owns or is tied to, and what that costs.
If the firm trades with you as principal or between client accounts, does it explain that?
Trading with clients as principal or between client accounts
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Any bond purchased by our clientele is processed as a Principal Transaction.p. 14
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether the firm ever trades with you from its own account or between its clients, and how you are protected.
If the firm gets research or services from a custodian or broker, does it explain them?
Research or services received from a custodian or broker (soft dollars)
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
As such, we will also have access to research products and services from your account custodian.p. 15
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?CoveredStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
These products may include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities.p. 15
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk what the firm receives from the custodian or broker it uses for you, and whether that costs you anything.
Do they earn commissions on products, and do they say so?Brochure Sales Compensation60/100
When a firm or its people sell products for a commission, the SEC asks the brochure to say so, name the pull, and tell you whether you could buy elsewhere.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it say that earning commissions is a conflict of interest?CoveredItem 5.E.1
A firm paid to sell a product has a reason to recommend it that has nothing to do with you.
This practice presents a conflict of interest because our firm may have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on your needs.p. 6
- Does it say commissions can shape what they recommend?CoveredItem 5.E.1
Naming the pull is the first step to controlling it; silence leaves it working on you.
This practice presents a conflict of interest because our firm may have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on your needs.p. 6
- Does it say you can buy the same products elsewhere?Not found in the brochureItem 5.E.2
You may be able to buy the same product for less somewhere else.
What to askAsk whether you could buy any recommended product through another broker or insurer.
- Does it say whether commissions lower your advisory fee?Not found in the brochureItem 5.E.4
If the firm earns a commission and the full advisory fee, you pay twice for one recommendation.
What to askAsk whether any commission the firm earns is credited against your advisory fee.
Do they get free research or services from brokers, and does it affect you?Brochure Soft Dollars30/100
When brokers give the firm research or services in return for your trades, the SEC asks the brochure to say what the firm gets and what it may cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it list what the firm gets from brokers for free?CoveredItem 12.A.1.e
Research, software and data paid for by your trades are a cost you never see.
These products may include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities.p. 15
- Does it say the firm benefits by not paying for those things?Not found in the brochureItem 12.A.1.a
A perk the firm would otherwise buy is money in the firm's pocket, paid with your trades.
What to askAsk what the firm would have to pay for those services if it bought them itself.
- Does it say those perks can shape which broker it picks for you?Not found in the brochureItem 12.A.1.b
Your trades should go where you get the best deal, not where the firm gets the best perks.
What to askAsk how the firm chooses the broker for your trades and whether perks play any part.
- Does it say whether those perks stay within what the law allows?Not found in the brochureItem 12.A.1.e note
The law allows research paid for with client trades only within limits; outside them, it is your money.
What to askAsk whether everything the firm receives from brokers is research the law lets it take in return for your trades.
- Does it say whether you pay more in trading costs because of those perks?CoveredItem 12.A.1.c
Paying up for trades to earn the firm a perk comes straight out of your returns.
However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge.p. 15
- Does it say whether every client benefits or only some?Not found in the brochureItem 12.A.1.d
Your trades may be paying for research that helps other clients' accounts, not yours.
What to askAsk whether the research your trades help pay for is used for your account.
A point not found is not a finding against the firm; many points apply only when the firm has that arrangement, and state-registered firms file the same brochure form.
Next Steps
Advisor Roster
4 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Daniel A Sullivan | 707476 | — | — |
| Nathaniel Louis Ralston | 6076209 | — | — |
| Douglas Paul Ralston | 370414 | — | — |
| Mario Milio | 7370319 | — | — |
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
What does dual registration mean for me?
It means your advisor can act as a fiduciary (putting your interests first) for some services and as a broker (suitability standard) for others. The key question to ask: 'For this specific recommendation, are you acting as my fiduciary?' Get the answer in writing.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
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Last scored: · Score version: 3.15 · CRD #7320