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Which of the following policies is not among the minimum policies specified in the Compliance Program Rule?

a. Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios with clients' investment objectives, disclosures by the adviser, and applicable regulatory restrictions.
b. Oversight of relationships between the adviser and third-parties.
c. Trading practices, including procedures by which the adviser satisfies its best execution obligation, uses client brokerage to obtain research and other services (soft dollars), and allocates aggregated trades among clients.
d. The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisement.

1 Answer

3 votes

Final answer:

The policy not among the minimum policies specified in the Compliance Program Rule is b. Oversight of relationships between the adviser and third-parties, while portfolio management, trading practices, and accuracy of disclosures are specified.

Step-by-step explanation:

Among the choices provided, the policy not among the minimum policies specified in the Compliance Program Rule is b. Oversight of relationships between the adviser and third-parties. The Compliance Program Rule generally includes requirements for portfolio management processes, trading practices, and the accuracy of disclosures made to investors, clients, and regulators. These are integral to maintaining a fair and transparent advising environment and are closely monitored to ensure compliance with regulatory standards. The oversight of adviser and third-party relationships is important, however, it is not explicitly stated as a minimum requirement in the Compliance Program Rule. The policy that is not among the minimum policies specified in the Compliance Program Rule is b. Oversight of relationships between the adviser and third-parties.

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