Portfolio Management & Trading & Rule 2790

The Portfolio Management and Trading Compliance module provides the ability to automate several sections of your firm’s Portfolio Management and Trading compliance:

• Monitoring Suitability
• Supervising Client and Offering Memorandum Mandates/Restrictions
• Trade Allocations – Pro Rata, Targeted or Departures
• Trade Error Log
• Principal, Agency Cross and Cross Transactions
• Rule 2790 – Restricted Persons participation in hot issues
• ERISA Compliance

The TurboCompliance^® Development Team works in concert with your CCO to encode each of your firm’s suitability parameters, client/offering memorandum restrictions as well as formulating the automation of each standard allocation method (e.g. prorata and target).

When Aggregation applies, TurboCompliance shall assign the appropriate pricing -- for example the average price of the security for that business day -- with transaction costs allocated pursuant to trade participation.

Since this section provides sample compliance procedure language, you must register for a TurboDoc Share Account in order to obtain access; please click here to request access.

In this section we provide a compliance practice guide which addresses:

• Fiduciary Duty
• Suitability of Investment Advice
• Managed Accounts
• Private Fund Clients (aka Hedge Fund Investors)
• Rule 2790
• Short sales
• Allocation of securities
• Required aggregation of orders
• Standard allocation methods
• Departures from standard allocation
• Required written allocation statements
• Recordkeeping
• CCO approval procedures
• CCO periodic reviews
• Trade Tickets
• Trade Reconciliation procedures
• Principle Transactions procedures
• Agency Cross and Cross Transactions procedures
• Required enforcement and annual review
• Forensic Testing