Commitment to Compliance
September 17 | Philadelphia
Conquering Current Compliance Challenges
Sept. 26, 2018 | 2:00 - 2:30 PM EST
 
RECORDED WEBINARS

Conquering Current Compliance Challenges
Recorded: August 15, 2018 
  Includes: 23 Best Practices, 5 Peer-tested tools and 15 No Action Letters

The SEC Examinations Priorities Handbook
Includes: 28 Best Practices, 20 Document Request Letters and 6 OCIE Risk Alerts

Cybersecurity Strategies to Ensure SEC Compliance, 2nd Edition
Includes: 24 Best Practices, 16 Tools, 4 Risk Alerts and IM Guidance

 
BEST EXECUTION OVERVIEW
Remember, you don't have to achieve best execution but you should seek it. As a 2001 speech by former OCIE Director Lori Richards makes clear, this is a legal obligation - stemming from your fiduciary duty to your client. She said advisers are "required to 'periodically and systematically' evaluate the quality of execution services received from the broker-dealers that are used to execute fund trades."
 
Where an adviser has responsibility to direct client brokerage, it has an obligation to seek best execution of clients’ securities transactions. In meeting this obligation, an adviser must seek to obtain the execution of transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances. In assessing whether this standard is met, an adviser should consider the full range and quality of a broker’s services when placing brokerage, including, among other things, execution capability, commission rate, financial responsibility, responsiveness to the adviser, and the value of any research provided.

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