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💗 · 2025年06月11日

佣金

NO.PZ2023021602000036

问题如下:

Carter works for Invest Today, a local asset management firm. A broker that provides Carter with proprietary research through client brokerage arrangements is offering a new trading service. The broker is offering low-fee, execution-only trades to complement its traditional full-service, execution-and-research trades. To entice Carter and other asset managers to send additional business its way, the broker will apply the commissions paid on the new service toward satisfying the brokerage commitment of the prior full-service arrangements. Carter has always been satisfied with the execution provided on the full service trades, and the new low-fee trades are comparable to the fees of other brokers currently used for the accounts that prohibit soft dollar arrangements.

选项:

A.A. Carter can trade for his accounts that prohibit soft dollar arrangements under the new l low-fee trading scheme.

B.Carter cannot use the new trading scheme because the commissions are prohibited by the soft dollar restrictions of the accounts.

C.Carter should trade only through the new low-fee scheme and should increase his trading volume to meet his required commission commitment.

解释:

The question relates to Standard III(A)-Loyalty, Prudence, and Care. Carter believes the broker offers effective execution at a fee that is comparable with those of other brokers, so he is free to use the broker for all accounts.

Answer B is incorrect because the accounts that prohibit soft dollar arrangements do not want to fund the purchase of research by Carter. The new trading scheme does not incur additional commissions from clients, so it would not go against the prohibitions.

Answer C is incorrect because Carter should not incur unnecessary or excessive "churning" of the portfolios (excessive trading) for the purpose of meeting the brokerage commitments of soft dollar arrangements.

这种用新service的佣金用于支付以前服务这个没有违反吗

1 个答案

王暄_品职助教 · 2025年06月11日

新服务的低价纯执行交易佣金仅用于完成既有佣金承诺,且不涉及用客户资金支付研究报告费用(符合禁止软美元账户的要求)。只要新服务的执行质量和费用与其他经纪商相当(题目已说明),且不导致过度交易(C选项的错误之处),这种安排就是合规的。核心在于确保客户利益优先,不滥用佣金安排。

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2024-05-17 17:30 1 · 回答