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Document trans with borkers involving SD arrangements, icnluding: list of proprietary and third party research providers, and description of the service and products received from providers
- must include whether traded on principal basis or not
- overheard ibankers in elevators -> violate- overheard CEOs
discussing in restaurant -> not violate- overheard CEOs discussing in
elevators -> violate
When analyzing investments, making recommendations, and taking
investment actions use diligence, independence, and
thoroughness.Investment analysis, recommendations, and actions should
have a reasonable and adequate basis, supported by research and
investigation.The application of this Standard depends on the investment
philosophy adhered to, Members' and Candidates' roles in the investment
decision-making process, and the resources and support provided by
employers. These factors dictate the degree of dili
- make sure: research directly benefits clients. sometimes: pay
attention to type of clients and types of research to see if they are
consistent
directed brokerage: disclose in writing, or disclose to client ouir
duty to seek best execution,only recommended to seek written
acknowledgement from client or assurance from fiduciary that directed
brokerage benefits client
violate iII(D) -client - presentation
Proxies have economic value to the client. To comply with Standard
III(A), the analyst is obligated to vote proxies in an informed and
responsible manner. A cost benefit analysis may show that voting all
proxies may not benefit the client, so voting proxies may not be
necessary in all instances. .
Directed brokerage occurs when the client requests that a portion of
the client's brokerage be used to purchase services that directly
benefit the client. Although, this may prevent best execution, it does
not violate the Standards as it was directed by the client, not the
brokerage firm
- report is updated at least annually- prohibits sharing entire report
w recommendation w client- interraction w ibanking must go thru the
compliance dept.- doesn't need to disclose if involved in an IPO. only
have to disclose if manage or co-manage- can't trade in contrary to the
employee or firm's most recent published recs.
...
- recommended to provide: client's specific product/services, total
brokerage paid from all accts under manager's discretion- not required
to report client's directed if less than 10 percent
- written instructions from client that restate manager's continuing responsibilities to seek best execution
...
- firm wide:description of all services
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