Code of Ethics
Trading
Marketing
Policies and Procedures
Potpourri
100
Emailing confidential information such as account numbers, SSN#'s etc. require this delivery method.
What is ZIX Mail?
100
This principle is defined as "acting in the best interest of the client."
What is a fiduciary?
100
This statement is not allowed in our marketing materials: Cynde Lee had the following to say about her Wealth Management firm, "SHGA is the BEST Wealth Management firm, they helped us organize our financial life, worked with our estate attorney and CPA to ensure our financial goals will be met."
What are testimonial statements?
100
Employee phone tree, key vendors, facilities and data recover are a part of this document, and is easily located here.
What is SHGA's business continuity/disaster recovery plan in SCT?
100
SHGA currently has custody on client accounts in these three ways.
What is 1) acting as Trustee, 2) login access to a client's account as the client, 3)bill pay?
200
Employee black out periods are in effect during these times.
What is firm rebalancing?
200
Investment Strategy, client restrictions and special client circumstances are documented here.
What is an IPS?
200
These types of statements are not allowed in our marketing collateral. SHGA is the best RIA firm in the SF Bay Area. SHGA guarantees a net performance of 20% per year. SHGA manages approximately $5 billon in discretionary assets.
What are false/misleading statements?
200
Four obvious ways YOU can protect a client's privacy.
What is 1) a clean desk, 2) keep your passwords secure, 3) lock file cabinets, 4) don't discuss clients in public areas?
200
All Employee smart phones and tablets must have this in place for security.
What is a password?
300
Employee equity or ETF trades where the security is on the SHGA restricted list are required to receive this from the CCO or a member of the Executive Committee.
What is pre-approval?
300
This group provides governance over strategy asset allocation, individual manager performance, and new investment strategies.
What is Investment Committee?
300
This is the correct way to state our AUM.
What is including the "as of date"?
300
Name six things that should be covered in a client's annual review.
What is to review the following: 1) change in financial situation, 2) non-core holdings, 3) unsupervised assets, 4) client restrictions, 5) interested parties and 6) risk tolerance?
300
New clients are required to receive the following disclosure documents before or at the time of signing with SHGA.
What is ADV, privacy policy and an offering of proxy guidelines?
400
The reason SHGA employees are prohibited from accepting an all expenses paid trip to the Super Bowl from Blackrock.
What is a Conflict of Interest?
400
A client may select a particular broker to execute some or all transactions for his/her account.
What is Directed Brokerage?
400
When an existing client is changing their strategy they are required to also receive this document.
What is a complete composite presentation?
400
SHGA's policy is to continue trading unless instructed by the executor of the estate in this instance.
What is the death of a client?
400
These three disclosures are required when showing performance of a third party to a client, or prospect.
What is source of information, is the performance net or gross of fees, and indicate that past performance is not indicative of future performance?
500
Employees must report these to the CCO within 45 days of quarter-end.
What are brokerage statements, and new accounts?
500
Executing a discretionary trade in a non-discretionary account. Entering an order to sell rather than buy or vice versa. Sending the trade to an incorrect broker.
What are trade errors?
500
Accepting endorsements or communicating with clients is prohibited on this medium.
What is LinkedIn?
500
If the company business has a material change at any time, we are required to update this document and deliver a copy to all clients.
What is SHGA ADV?
500
Going forward Client Annual Review forms and other firm workflows will be documented in this software.
What is Salesforce?
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