B. Fair Dealing.
#analyst-notes #code-of-ethics-and-standards-of-professional-conduct #iii-duties-to-clients
Procedures for compliance
- Limit the number of people involved.
- Shorten the time frame between decision and dissemination.
- Publish personnel guidelines for pre-disseminations.
- Disseminate information simultaneously to all parties.
- Maintain a list of clients and their holdings.
- Develop and disclose written trade allocation procedures.
- Establish systematic account review.
- Disclose levels of service.
Members and their firms are required to take the following steps to ensure that adequate
trade allocation practices are followed:
- Obtain advance indications of client interest for new issues.
- Allocate new issues by client rather than by portfolio manager.
- Adopt a pro rata or similar objective method or formula for allocating trades.
- Treat clients fairly in terms of both trade execution order and price.
- Execute orders in an efficient and timely manner.
- Keep accurate records of trades and client accounts.
- Periodically review all accounts to ensure that all clients are being treated fairly.
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