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

SECURITIES FIRM MANAGEMENT

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.

  • Through recruiting, promotions and policies, senior management should develop a corporate culture of placing client interests first.
  • Employees who fail to meet a firm's standard of placing client interests before their self-interest should be disciplined.
  • Branch managers should have the appropriate resources to supervise the RRs for whom they are responsible.
  • Branch managers should be charged the compliance costs of monitoring those RRs.
  • Compliance departments should be involved in new product development.
  • Compliance departments should be involved when recruiting experienced RRs.
  • Information systems should be able to match client transactions against client objectives.
  • "Risky" investments should be treated differently from other investments before a client presentation is made.
  • RRs should not be pressured to sell particular investments.
  • RRs should not be pressured to sell securities from a firm's inventory.

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