Best Practices

Compensation Practices Information to Retail Client
Firm Management Investor Responsibilities
Internal Firm Policies Investor Rights
Relationships With Regulators Financial Needs Analysis
Role of Compliance Professionals Investor Confirmations
RR Training Investor Complaints
Soft Dollar Sales Supervision

COMPENSATION PRACTICES

Information to Retail Client, Securities Firm Management, Registered Representative Training and Compensation Practices were issued on April 10, 1995 by a committee established by Securities and Exchange Commission Chairman Arthur Levitt, Jr. The panel studied how management practices, including compensation, affect client-broker relationships. Daniel Tully, Chairman of Merrill Lynch & Co., served as the committee's chairman. Other members were: Warren Buffett, Chairman of Berkshire-Hathaway, Inc.; Samuel Hayes, a Professor at the Harvard Business School; Raymond A. Mason, Chairman of Legg Mason, Inc. and former SIA Chairman; and, Thomas O'Hara, President of the National Association of Investors Corp.

  • Payments to registered representatives should be identical for a firm's own investment products, such as proprietary mutual funds, and for investments within the same product category marketed by a firm but created by other organizations.
  • "Appropriate" disclosure should be made to clients of temporary accelerated payouts to representatives.
  • Sales contests on single products should be prohibited.
  • "Appropriate" disclosure should be made to clients of any bonus payment a registered representative receives for joining a firm. Such bonuses should be paid over several years.
  • Some part of RR compensation should be deferred for several years and payment linked to the RR's compliance record.
  • In part, RR compensation should be based on client assets, regardless of transaction activity.
  • New RRs should receive a base salary, which should be supplemented according to their productivity.
  • Brokerage firm stock should be part of an RR's compensation.

For more information on Best Practices, please contact Don Kittell.

(Adopted by the Board November 1996)