March 2011
Beginner
192 pages
4h 30m
English
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CURRENT SMA EXAM ISSUES
As registered investment advisers, both sponsors and money managers are subject to regular examinations by securities regulators. In recent years, the SEC has focused on the following issues in its examination of SMA programs:
- Best execution
- Suitability
- Fee calculations
- Disclosures
- Rule 3a-4 compliance16
The issue of best execution has become a significant focus of regulators. Investment advisers are required to act in the best interest of their advisory clients. Part of that obligation includes obtaining the best price and execution for their securities transactions. The SEC defines “best execution” as “seeking the best price for a security in the marketplace as well as ensuring that, in executing client transactions clients do not incur unnecessary brokerage costs and charges. To seek to obtain best execution, advisers must periodically evaluate the execution performance of the broker-dealers they use to execute client transactions.”17 Two of the most common deficiencies found by the SEC in the area of best execution are (1) inadequate internal controls related to brokerage arrangement and execution, and (2) failure to disclose conflicts of interests related to brokerage arrangements.
Both sponsors of SMA programs and money managers in SMA programs have an obligation to determine whether the SMA is suitable for the investor client; this suitability obligation stems from the Advisers Act.
Rule 3a-4 does not specifically define suitability, but it is commonly ...
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O’Reilly covers everything we've got, with content to help us build a world-class technology community, upgrade the capabilities and competencies of our teams, and improve overall team performance as well as their engagement.Julian F.
I wanted to learn C and C++, but it didn't click for me until I picked up an O'Reilly book. When I went on the O’Reilly platform, I was astonished to find all the books there, plus live events and sandboxes so you could play around with the technology.Addison B.
I’ve been on the O’Reilly platform for more than eight years. I use a couple of learning platforms, but I'm on O'Reilly more than anybody else. When you're there, you start learning. I'm never disappointed.Amir M.
I'm always learning. So when I got on to O'Reilly, I was like a kid in a candy store. There are playlists. There are answers. There's on-demand training. It's worth its weight in gold, in terms of what it allows me to do.