MEMORANDUM
To: A&M Investment Management Staff
From: Bill Post, Chief Compliance Officer & Co-National Practice Leader | A&M Investment Management, LLC “AMIM”
Subject: AMIM Best Execution Policy
Date: August 24th, 2016
Introduction
The U.S. Securities and Exchange Commission (“Commission”) position is that as a registered investment adviser under the U.S. Investment Advisers Act of 1940 should adopt written policies and procedures designed reasonably to ensure that the adviser satisfies the best execution for client trades.
The characteristics of the CD market presents A&M Investment Management (AMIM) with practical difficulties in assessing and documenting CD best execution not faced when undertaking, for example, equity transactions. Unlike their equity counterparts, the Certificate of Deposit (CD) market is fragmented and often subject to limited transparency as a result of the absence of a centralized market or formal exchange. CDs are traded Over-the-counter (OTC), via a dealer network, as opposed to on a centralized exchange.
This memo will state AMIM best execution policies and procedures tailored to AMIM’s operations and the types of fixed-income instruments (CDs) in which it trades.
This processes and procedures will create a systematic, repeatable, adaptable, and demonstrable approach to seeking best execution on an overall basis.
Background
Under a well-settled principle of law, AMIM is a fiduciary subject to a number of specific obligations when acting on
The US Securities and Exchange Commission (SEC) is the US federal agency that holds the primary mandate to enforce federal securities laws and regulations to control the securities industry and the country’s stock exchange and regulation of all activities and organizations including the US electronic securities market. The SEC is committed to promoting a market environment that yields public trust characterized by integrity to attain its mission of protecting investors through maintenance of fair and efficient markets through facilitation of capital information (Basagne, 2010). The SEC financing is a major area of focus since there has been major concern regarding the SEC agency financing and whether they utilize the
Additionally, we then develop plans to address those patterns and trends that show areas where we could improve our process. And finally, we continuously analyze all future data to identify areas of success and areas for improvement, ensuring that our work environment and outcomes for our stakeholders are of the highest quality.
The steps needed to assure that this process works or does what it is intended to are short yet effective. The first
There are many ideas about the correct basis for contractual obligation. They include promise, consideration, and cause. All jurisdictions follow at least one. In Thomas E. Davitt’s The Elements of Law, the author articulates a very credible argument for the basis for contractual obligation being one of those named above. Davitt simplifies the arguments for all of these and names one correct basis: the promise itself. Generally Thomas E. Davitt, S.J., The Elements of Law, 272 (1959). This paper will argue in favor of Davitt’s writings. The basis for contractual obligation is the promise itself. In order to effectively argue in favor of one basis over the possible others, it is necessary to discuss and rule out the others.
Title IX also requires the Securities & Exchange Commission to conduct studies on the financial literacy levels of retail investors and the current rules and regulations concerning brokers, dealers and investment advisors. The Government Accountability Office is also required to conduct studies on the potential conflicts of interest between the investment bankers and analysts within the same firm and on mutual fund advertisements with a particular focus on the use of past performance data in marketing
There are several variations to the performance improvement process with most following a version of the PDCA cycle: plan, do, check, act. The "plan" identifies the nature of the problem, obtains the resources to resolve it and determins the best way to implement any change required. The "do" is the actual changing of an existing process. The "check" uses key performance indicators to measure and ensure that the new process is performing as expected. The "act" brings deviations to the change to make the underlying process as efficient as possible.
The objectives of both parties in these particular exchanges are to obtain the best accounts available to their teams to maximize profit for the company and commissions for their staff. As well as, to get their points across but they are both looking out for the best interest of their groups. On one side, Marilyn would like to share accounts rather than being left with bad accounts with no potential, while Len would like to work on accounts that will generate a high commission.
The process is thorough, includes multiple perspectives, utilizes several methodologies and clearly correlates with the stated impact area.
Our team recognizes Harry’s reminder as a wise disclaimer to provide to the client. Those who are unfamiliar with the portfolio management rely on past performing capital generators and hope for the identical result. Harry is making sure that the client understands that the market is volatile and is unpredictable. With 60% of the assets allocated to equities in a small-mid cap fund, a great deal of fluctuation can take place during the accumulation period. Harry wants to ensure the portion allocated in this market is tracked carefully and ensure major losses are avoided. Harry must include a statement that assists the client in understanding how the growth in their portfolio can fluctuate. Often times, clients are blinded by short term results. Harry’s Job is to ease the emotions of the clients and act in a way that has their best interest to achieve their financial goal. With the Robinson’s goal in mind, harry must not only consider the fiduciary standards when it comes to investment advice, but build on the foundation the Robinson’s are looking to
What are a couple of requirements under the prudent investor rule that pertain to investment advisors?
Monegain (2011) shares some results from 344 respondents to a survey regarding CDS tools. The survey showed
using trail and error. By doing this they are able to take the best approaches and eliminate the
The framework requires a rather meticulous approach to implementation. In order to establish a systematic approach and guarantee positive results, your should take the following steps:
A Methodology “is a documented approach for performing activities in a coherent, consistent, accountable, and repeatable manner“.
Brigham, Eugene F., and Joel F. Houston. Fundamentals of Financial Management. Thomson: South-Western Publishers, Eleventh Ed. 2007.