A+ 2025/2026
✔✔Impersonal Advisory Services - ✔✔Advisory services not tailored to individual clients
✔✔State Notice Filing - ✔✔Requirement for SEC-registered IA with 5+ clients in a state
✔✔Client Definition (Adviser's Act) - ✔✔Includes natural persons, trusts, and legal
entities receiving advice
✔✔Suitability - ✔✔Recommendations aligned with client's situation and goals
✔✔Fulfilling Suitability Obligation - ✔✔Providing impartial advice matching client needs
with care
✔✔Client Investment Objectives/Restrictions - ✔✔Matching decisions with mandates,
profiling, and agreement execution
✔✔Safe Harbour Rule - ✔✔Provides exemptions for certain investment advisory
programs
✔✔Principal/Agency Cross Transactions - ✔✔Transactions involving adviser, clients,
and brokerage
✔✔Riskless Principal Trade - ✔✔Adviser buys/sells securities after finding buyer/seller
✔✔Disclosure for Principal Transactions - ✔✔Advisor must disclose acting as principal
before client consent
✔✔Temporary Rule for Principal Trades - ✔✔Expired rule allowing IAs dually registered
as BDs to engage in principal transactions
✔✔Agency Cross Trade - ✔✔Trade between client accounts arranged by advisor
✔✔Fiduciary Duty (Aggregate Trade Orders) - ✔✔Fair distribution of transaction costs
across traded accounts
✔✔SEC's Stance on Securities Pricing - ✔✔Advisers must value client holdings
accurately to assess fees
✔✔Securities Valuation Principles - ✔✔Assets valued at market price or fair valuation if
market price unavailable
, ✔✔Written Policies for Securities Valuation - ✔✔Policies should be clearly defined and
understandable
✔✔Securities Valuation Disclosure - ✔✔Includes transparency, risk disclosure, and
conflict mitigation measures
✔✔Consistent Securities Valuation - ✔✔Clear procedures for pricing and valuation
consistency
✔✔Valuation Policies - ✔✔Identify parties, methodologies, pricing sources, and conflict
management in investment valuation
✔✔Trade Errors Correction - ✔✔Client must not be disadvantaged, adviser bears costs,
and soft dollars cannot be used
✔✔Documentation Requirements - ✔✔Include procedures for violations prevention,
detection, corrections, and regular process reviews
✔✔Soft Dollars - ✔✔Adviser obtains non-execution services from BD in exchange for
trade direction
✔✔Soft Dollar Arrangements - ✔✔Include proprietary research, third-party research,
and commission sharing programs
✔✔Three-Step-Test - ✔✔Evaluates Safe Harbour eligibility, lawful assistance, and
reasonable value determination
✔✔Mixed-Use - ✔✔Client commission services with both eligible and non-eligible uses,
requiring cost allocation
✔✔Brokerage and Research Services - ✔✔Includes advice, analysis, reports, and pre-
transaction services provided by BD
✔✔Directed Brokerage - ✔✔Client-requested or adviser-required trade direction to a
specific BD
✔✔Best Execution Factors - ✔✔Consider price, research value, execution capability,
costs, and client value maximization
✔✔Adviser's Best Execution Duty - ✔✔Obligation to execute transactions favorably for
clients considering various factors
✔✔Insider Trading - ✔✔Trading with material non-public information, violating trust, with
wrongful intent