Policies & Procedures
Code of Ethics (Firm "10 Commandments")
Acronyms
Compliance Fails
For Fun
Investment team Know How
100
An email comes in from Drew asking for to transfer funds for him. This should be your next step.
What is contact Drew or IT by another method to verify the email is legitimate?
This should raise suspicion for every one of us. The first step is to reach out via teams to Drew or IT for confirmation of this request.
100
This is our limit for Gifts & Entertainment without pre-approval.
What is the value above $500 or considered lavish gift?
Example – a client wants to lend you his airplane for the weekend, this is considered a lavish gift as well as over our allowable limit. A client or outside consultant offers you Red Sox tickets. If it falls under our limit (not an entire box), then you should go ahead and accept. No prior approval is needed. Keep in mind this is a one-time per year $500 limit, or cumulative within a year.
100
AML
What is Anti-Money Laundering?
An example is sending transactions through multiple financial institutions to limit tracking.
100
Although the SEC marketing rule allows these, we have a policy against using them.
What are testimonials or endorsements?
Any statement testifying to someone’s character or qualifications. Such as stating how wonderful we are.
100
This recording artist’s 2023 tour was the first tour to earn over $1,000,000,000.
Who is Taylor Swift?
100
All investment decisions and recommendations for a client on a discretionary basis must comply with which document?
What is the client’s Investment Policy Statement (IPS)?
Also, all investment accounts must be reasonably close to the target allocations unless the account is in a state of transition. Full-blown IPS is recommended but not required. An email agreeing to the investment philosophy may take its’ place if needed. Use your judgment to decide when to seek compliance review. Make customized instructions conspicuous. If you put customized instructions in IPS, how will others working on these relationships know about them?
200
This policy says our responsibility is to make sure all business relationships meet ethical standards of due care. We try to mitigate these.
What are Conflicts of Interest?
Occurs when a client’s personal interests – family, friendships, financial, or social factors – could compromise our judgment and/or decisions. An example is when a couple are both remaining our clients although they are getting divorced.
200
Who is required to report brokerage accounts, personal or household if you have control, through Basis Code or manually if not listed in BasisCode?
Who is every employee?
Not just Access Persons but all employees are required to adhere to this rule.
200
CCRO
What is Chief Compliance & Risk Officer?
(Sean) The officer accountable for enabling the efficient and effective governance of significant risks, such as strategic, operational, financial, compliance, etc.
200
The trading of a company's securities by individuals with access to confidential or material non-public information about the company is called this.
What is Insider trading or trading on the restricted list?
Trading on non-public material information (MNPI) is illegal and we have a restricted security list for specific public securities. All securities on this list, whether for client or employee, require compliance pre-approval.
200
Will Ferrell played the oversized North Pole adoptee.
Who is Elf?
200
If you are a registered person (RIA representative) you are considered to be this.
What is an Access Person?
All client advisors, wealth planners and investment team members are considered Access Persons. (Registered with FINRA)
300
These documents get sent to all clients and trustees at least annually or when there is a material change.
What are the ADV 2A, 2B and 3 (form CRS)?
As required by SEC regulations. We pull this information from CRM. Additionally, the Form CRS (ADV 3) always goes with new account paperwork to the client. We also send the Privacy Notice annually, but are only required to send it at the beginning of the client relationship, then whenever there is a change.
300
This is the rule/duty that requires us to act in the best interest of our clients.
What is The Fiduciary Duty?
Our legal responsibility is to act solely in the best interest of the client first.
300
MNPI
What is Material Non-Public Information?
Anything non-public and not available through proper channels of inquiry (social security number, company private information, M & A proposals, new product development, etc.)
300
Your client handed you a check to deposit for him into his Fidelity account. You put it in your desk to deal with it the next day. This is what should have been done in this case.
What is hand check to the admin person for proper logging and mailing or depositing?
In the case where you received either a check or a security, immediately hand it off to the admin person in the office that day. Never leave it in a drawer or on someone’s desk.
300
One of the key flavors in eggnog is this spice.
What is nutmeg?
300
These must be reported immediately to the CIO, CCRO & Compliance team.
What are trade errors?
Trade errors must be dealt with immediately upon discovery to correct any mistakes made, but should be discussed with another trader (Chris P or Gordon) before taking corrective action. In some cases, the client will need to be notified. Whether it was a trade error, or planning error they need to be corrected. All traders should be reviewing the Trade Audit Log the next morning following a trade to capture any errors and mitigate any losses as early as possible. If the trader knows he/she will be out, you MUST request someone to cover for you and review your trades on your behalf for accuracy. All of the details must be included in the trade error log and signed off by the CIO.
400
It is our policy to generally not handle these items for clients.
What are proxies, securities or stock certificates?
If we make an exception to the proxy voting policy, it must be pre-approved by compliance for maintaining detailed documentation.
400
You just received a complaint from a client, who do you report this to?
Who is the CCRO (could be SCA or CEO)?
As soon as possible reach out to our CCRO, compliance team & your immediate senior manager. Very important, please document your call or email.
400
KYC
What is Know Your Client/Customer?
Identify and verify your client when opening an account. We can do this through drivers license, passport, etc.
400
You received and accepted an offer to a speaking engagement. You went ahead and did this on your own. You have missed these steps in accepting this offer.
What is request a compliance pre-approval for an OBA first?
You must request pre-approval for an Outside Business Activity (OBA) whether being compensated or not. You do this through our BasisCode software in OKTA.
400
This late artist, whose debut album “Space Oddity” was released in 1969.
Who is David Bowie?
400
Most investment performance or performance decks can be shared with prospects or clients. This should be your first action step.
What is to reach out to get compliance pre-approval prior to delivering this to a prospect/client?
Prior to delivering materials to clients/prospects, if a deck is not already pre-approved by compliance, you must reach out to the compliance team. If it has been pre-approved but you are making changes, other than updating to current numbers, you still must reach out again. Must include the full text of our disclosures. All performance exhibits for business development must be net of our fees.
500
We accept electronic signatures on all documents requiring signatures that support this capability.
What is DocuSign?
The team must confirm with client and advise a DocuSign document is coming over. The client team should verify that DocuSign will be accepted by the person requesting the final document (i.e., Our internal documents are fine to be signed via DocuSign, but if this is a CPAs document, for example, check with the CPA to make sure they will accept DocuSign.)
500
You just learned some inside information (or material nonpublic information) about a client. This falls under this part of the Code of Ethics.
What is confidentiality?
We always respect the confidentiality of our client relationships. We may not even discuss with other teams inside Ballentine Partners.
500
OBA
What is Outside Business Activity?
Any activity an employee is engaged in outside of their primary employment. Whether paid or unpaid (e.g. Board member, freelance work, consulting, etc.)
500
A client emails you to request funds be sent out to a third party. They ask you to call them back at a different phone number than previously given. You agree and call them to verbally confirm the instructions. You should have done this instead.
What is always call a client to confirm at the phone number we have on record?
This email sounds suspicious. We should always call using the phone number in CRM for proper verification of any email instructions.
500
Formula 1 raced up this famous road in this city.
What is Las Vegas? (Las Vegas Boulevard)
500
You are attempting to place a trade through Black Diamond but you realize you cannot (either too large, or some other reason). This is your next step.
What is write up a manual ticket to trade on a custodian’s website?
Manual trade tickets must be complete and accurate (use when trading outside of Black Diamond). They should be saved in the trade ticket folder on BF3.
1000
Once we adopt a self-imposed rule or procedure, it becomes this.
What is a requirement?
1000
Our client is emailing saying they want to invest in something that we do not recommend. We disagree with their decision and get it in writing, however we still need to take this step.
What is follow the client's instructions?
We need to follow the client's instructions even if we disagree. If this happens, always be sure document our stance and the client's decision.
1000
RAUM
What is Regulatory Assets Under Management?
RAUM, which is different from Assets Under Management (AUM), is designed to calculate gross assets under management for regulatory purposes.
1000
You send an email and realize moments later you sent it to the wrong person (outside the company). This should be your next step.
What is contact Compliance?
More often than not, you should only need to contact the unintended recipient to ask them to delete the email. However, if sensitive information was sent, you may need to do more. Contact Compliance for help!
1000
Reigning from 27 BCE until his death in 14 AD, he was the first Emperor of Rome.
Who is Caesar Augustus? (aka Octavian)
1000
_______ must be kept of all formal investment team meetings, including a list of those in attendance.
What are minutes?
This is a book and records requirement.