CFA三级

C.Trading Managers must:

1.Give priority to investments made on behalf of the client over those that benefit the Managers’ own interests.

I.Managers must not execute their own trades in a security prior to client transactions in the same security.

II.Investment activities that benefit the Manager must not adversely affect client interests. Managers must not engage in trading activities that work to the disadvantage of clients (e.g., front-running client trades).

III.Managers should develop policies and procedures to monitor and, where appropriate, limit the personal trading of their employees. In particular, Managers should require employees to receive approval prior to any personal investments in initial public offerings or private placements.

IV.Managers should develop policies and processes designed to ensure that client transactions take precedence over employee or firm transactions.

V.One method is to create a restricted list and/or watch list of securities that are owned in client accounts or may be bought or sold on behalf of clients in the near future; prior to trading securities on such a list, employees would be required to seek approval.

VI.In addition, Managers could require employees to provide the compliance officer with copies of trade confirmations each quarter and annual statements of personal holdings.

2.Use commissions generated from client trades to pay for only investment related products or services that directly assist the Manager in its investment decision-making process, and not in the management of the firm.

I.To determine whether a benefit generated from client commissions is appropriate, Managers must determine whether it will directly assist in the Manager’s investment decision-making process.

II.The investment decision-making process can be considered the qualitative and quantitative process and the related tools used by the Manager in rendering investment advice to clients.

III.The process includes financial analysis, trading and risk analysis, securities selection, broker selection, asset allocation, and suitability analysis.

IV.Some Managers have chosen to eliminate the use of soft commissions (also known as soft dollars) to avoid any conflicts of interest that may exist. Managers should disclose their policy on how benefits are evaluated and used for the client’s benefit.

V.If Managers choose to use a soft commission or bundled brokerage arrangement, they should disclose this use to their clients. Managers should consider complying with industry best practices regarding the use and reporting of such an arrangement, which can be found in the CFA Institute Soft Dollar Standards.

3.Maximize client portfolio value by seeking best execution for all client transactions.

I.When placing client trades, Managers have a duty to seek terms that secure best execution for and maximize the value of each client’s portfolio (i.e., ensure the best possible result overall). Managers must seek the most favorable terms for client trades within each trades’ particular circumstances (such as transaction size, market characteristics, liquidity of security, and security type).

II.Managers also must decide which brokers or venues provide best execution while considering, among other things, commission rates, timeliness of trade executions, and the ability to maintain anonymity, minimize incomplete trades, and minimize market impact.

来自：金程CFA