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INVESTING & TRADING
FINANCIAL PLANNING
- Financial Plan Development
- Financial Plan Implementation
- Investments
- Research Information
- Retirement Plans
TRADING
- Broker-Dealer & Market
- Selection
- Trades
- Agency Cross Transactions
- Allocating Trades
- Best Execution
- Client Securities Orders
- Order Management Systems
- Suitability
- Trade Entry
- Trade Ticket
- Types of Trading
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Client Securities Orders
Suitability
- Before recommending a particular security, the investment adviser representative must have reasonable grounds for believing that the recommendation suits the needs of the client. The investment adviser representative also must have a through understanding of each investment product he or she is recommending. Such determination should be based upon a number of factors, including the client's:
- financial condition;
- other security holdings;
- tax status;
- stated investment objective; and
- client risk profile.
The adviser should maintain suitability information about each client and refer to this information prior to making securities recommendations or placing securities orders for the client.
An investment adviser representative may refuse to initiate a transaction at the client's request that is unsuitable for the client. In this case, the investment adviser representative should explain to the client why the trade is unsuitable. The relevant facts concerning each trade rejection should be recorded and maintained.
Current information about the client's financial status and investment objectives must be maintained and made available to the investment adviser representative in order for such person to make suitability determinations.
Mutual Funds
- Before recommending that a client switch mutual funds, it must be determined that the transactions are in the best interests of the client. Explain to the client that the switching will result in the client paying a sales load or other transaction cost.
- Before any mutual fund transaction, carefully review with the customer the sales loads and any other charges applicable to the purchase. If the fund offers multiple classes of shares, the different costs applicable to each class of shares should be explained to the investor.
Best Execution
Take steps to ensure that the client will pay a fair commission to the broker-dealer for execution of the order.
Telephone Orders
- Obtain client's permission to record the telephone conversation by:
- Securing written consent to record conversations between the client and firm;
- Verbally informing client that the conversation is being recorded at the beginning of the conversation and record such notification; or
- Using a beep-tone recording device that beeps every 15 seconds during the conversation;
- Obtain a blank order ticket and write down the client's order;
- After the order has been communicated by the client, read back the order to the client in its entirety; and
- Report any unusual or sizeable order to the appropriate firm officer as soon as reasonably possible.
Order Procedures
- Obtain a blank order ticket;
- Write the client's name, account number, date and time on the order ticket.
- Verify that the proposed investment is suitable for the client.
- Indicate whether the trade is discretionary or non-discretionary.
- Fill out information about the transaction (e.g., name of security, purchase/sale, and amount of securities).
- Write down broker-dealer through whom trade is executed.
- Repeat order to client.
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