Propose practices and procedures that stop breaches of the ethics Code and the Standards of Professional Conduct before they occur

Firms should write down what a reasonable basis means: due diligence steps for internal and outside research, criteria for approving data vendors and subadvisers, and independent validation and stress testing of models before they are used. For communication, standard disclosures covering services, all costs to the client, the process, and its risks and limitations work well, with a trigger to tell clients promptly when the process changes and a rule that forecasts are labelled as opinion. For records, a written retention policy that meets local rules, or keeps records for at least seven years where there are none, held centrally because records are firm property. The trap is assuming onboarding disclosure is enough; the duty is ongoing.