Code of Ethics
Record Keeping
Privacy
Hodge Podge
Patriot Act/AML
100
The duty that requires CSSCIAS and its advisors to act in the best interest of its clients.
What is fiduciary
100
Written record documenting discussions with clients to substantiate recommendations and the fulfillment of client requests that is stored electronically in a client’s files.
What are client meeting notes?
100
Personally identifiable information that is provided by a consumer to a financial institution that is not generally common knowledge.
What is nonpublic personal information?
100
Accounts you own or have a beneficial interest in that are not held through CSSC/Pershing .
What are outside brokerage accounts?
100
The Act that requires SEC registered investment advisers to maintain policies and procedures to enhance compliance with the federal securities laws.
What is the Investment Advisers Act of 1940?
200
Questions in interpreting the Code of Ethics should be directed to this person.
Who is the Chief Compliance Officer?
200
Holding onto a client’s check overnight.
What is custody?
200
People using client nonpublic personal information to gain access to clients’ custodial account(s) are engaged in this.
What is identity theft?
200
Prohibits members of associated firms from giving or receiving anything of value over $100 in relation to the recipient’s employer’s business.
What is Gifts and Gratuities Rule?
200
The Act that sets forth requirements for institutions to undertake anti-money laundering efforts.
What is the U.S. Patriot Act?
300
Knowledge about a company that has not been publicly disclosed and could affect the market price of the company’s securities.
What is material nonpublic or insider information?
300
Tax Lien, bankruptcy, judgment
What are reportable items on Form U4?
300
Erasing information stored on electronic media and shredding paper documents are examples of this.
What are proper disposal procedures?
300
The requirement that every registered investment adviser deliver to each prospective client a written disclosure describing the background and business practices of the adviser.
What is the brochure rule?
300
Clients transaction patterns show a sudden change inconsistent with normal activities.
What is an AML Red Flag?
400
Acting on information that has not yet been made publicly available.
What is insider trading?
400
SEC Registered investment advisers must comply with this organization’s record keeping requirements.
What is the SEC?
400
The document CSSC is required to send annually detailing how client information is secured.
What is the Privacy Notice?
400
Participating in private securities transactions without providing prior written notice to, or prior written approval from your broker-dealer.
What is selling away?
400
Record client’s driver’s license or similar government issued identification, along with other information.
What is Client Identification Program?
500
An Access Person having indirect interest (the ability to profit) in reportable securities.
What is beneficial ownership?
500
Broker Dealers must comply with this organization’s record keeping requirements.
What is FINRA and the SEC?
500
This Regulation requires CSSC to establish appropriate standards concerning the security of client nonpublic personal information.
What is Regulation S-P?
500
Serving as trustee for a non-immediate family member.
What is an outside business activity?
500
Investment advisers have special fiduciary responsibilities as administered by the U.S. Department of Labor.
What is the Employee Retirement Income Security Act of 1974 (“ERISA”)?