Propose practices and procedures that head off breaches of the Code and Standards under Standard III, Duties to Clients

Fair dealing is best protected by a written allocation policy fixed before orders go out: allocations recorded on time-stamped tickets, partial fills shared pro rata at the average price, and hot issues offered only to accounts for which they are suitable, with employee accounts last. Suitability needs a written IPS for each separate account, reviewed at least annually and whenever the client's circumstances change, plus pre-trade checks that block orders breaching mandate limits. A written proxy-voting policy and a soft-dollar policy, ideally following CFA Institute's Soft Dollar Standards, support loyalty, with the use of client brokerage reported to clients. Complying with GIPS, and claiming it, gives performance presentation a tested framework, and access controls on client files protect confidentiality.