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The Investment Manager should assure that, over time, all Clients
receive the benefits of Research purchased with Client Brokerage.1.
Agency Trades. ok to use client brokerage to purchase research that is
not useful for that client now, but must ensure in other times this
client will be compensated 2. principal trade: client brokerage must
beneficial the client if not manager must obtain prior consent from
client to use it for other accounts
office equipment - nofinancial tv - yes if use in decision
makingbloomberg - no even it is used for client acceess to info, only
yes if used for decicion making. if both then sharesoftware and
computer- share, must be reevaluate annually.
only require disclosure if firm manage or co-manage the deal
not allowed unless extreme hardship. must provide personal investment of self and family at least annually
no
prohibit under all circumstance without the permission of the investor
can accept travel expense but nothing else
quarter and must issue a final report to clients
recommendation can be group concensus. the boss can put name on report if he invloved in the process
must disclose the achieved result was a team effort and can only claim for a portion in this result
yes, because new prudent only evaluate the portfolio as a whole
request written instruction that restate the manager on going responsibility to seek best execution
60days
candidate cannot usecharterholder can use on biz card or letterhead of individual not in company letterhead
seeking best execution, minimizing cost and use client brokerage for client benefit
must be documented and go through compliance
violate if not correct the audience
loyalty to employer firstthen integrity of market
no
cannot disclose which accounts are under managment even when told by a
friend of the investor that he knows this investor has account with u
if selling current holdings not make sense to generate cash then investment manager can stop buying hot stocks
use the more strict rule. raw data feeds not added value research
yes
must address whether trades generating brokerage involved transaction conducted on a principal basis
not only officers and their direct reports but also to other investment pro who have employees subject to their control
7 yrs
it is ok eg if the firm use top down or macro then technical or quant can be removed if required by the managers
report abt yourslefencourage others / remind others to report, not required to report violation of others
not allowed
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