Trading Compliance: Best Execution, Soft Dollars and Directed Brokerage

Course Description

As a fiduciary, an investment adviser has many obligations to the client including developing, implementing and testing policies, procedures and disclosures to ensure proper trading practices. Compliance, legal and trading experts will offer an overview of the trading process and appropriate best practices, and provide “hands-on” compliance solutions for the following mission-critical areas: best execution, soft dollars, and directed brokerage.

This seminar will provide insight into the meaning of “best execution,” and will focus on how strong policies and procedures can help an investment adviser fulfill its fiduciary obligations. Attendees will also learn how to identify, mitigate and manage potential conflicts of interest in the trading process.

The seminar will also discuss the regulatory issues pertaining to “soft dollar” relationships. Section 28(e) of the Securities Exchange Act of 1934 provides a “safe harbor” for certain research and brokerage services received by an investment adviser in exchange for directing client commissions to a broker-dealer. The seminar will focus in particular on the definitions of eligible “research” and “brokerage services,” as defined by SEC interpretation.

Learning Objectives

After attending this course, attendees should be able to:

  • Meet relevant requirements to address disclosures and conflicts of interest that arise from an adviser’s fiduciary duty to seek best execution
  • Implement best practices relating to compliance documentation and monitoring processes relative to best execution, how to evaluate brokerage allocation and SEC guidance regarding soft dollars under Section 28(e)
  • Meet the relevant disclosure requirements for directed brokerage and consider the implications of the intersection of directed brokerage and best execution

For Whom: Chief Compliance Officers, Management Compliance Staff at all levels, Legal Counsel, Personnel involved with client reporting, composite performance reporting, determining assets under management for client billing, and/or trading and reconciliation of illiquid securities. Persons involved with monitoring client portfolios.

Suggested Skill Level: Intermediate

Instructional Method: Group Internet-Based and Group-Live

Pre-requisites for participation: No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940 to become familiar with the structure and terms.

Advance Preparation: None

Continuing Education Credits: TBD

NRS Continuing Education Guide