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Terms in this set (77)
Level 1 Fiduciary Gap Analysis and may be conducted by a trained
Assessment internal staff or by external fiduciary experts.
If deficiencies are identified, a competent assessor is
Level 2 Assessment
best positioned to conduct remediation.
Level 3 Assessment When all deficiencies are remediated
SEC requires designation of a chief compliance
officer for each RIA to ensure that the firm meets
CCO
fundamental fiduciary obligations in compliance with
the SEC.
The practice of plan sponsors and fiduciary advisors
Pension Protection Act of who are party to eligible investment advice
2006 (PPA) arrangements (EIAAs) must be examined as part of
the annual independent audit.
If applicable, these must be disclosed and approved
in writing. Under the investment advisers act, some
state laws, a "Cash Solicitation rule" requires special
Finders Fee
disclosures by the person referring prospective
clients to the RIA. And may trigger the registration of
that person as an investment adviser under state law.
, If applicable, as a best practice the dollars that are
rebated back to the plan should be allocated to those
Rev Share Best Practice
participants invested in the funds that include these
types of fees.
The policy and responsibility for who is to vote
proxies should be in the IPS., especially in ERISA
Proxy Voting plans. In case of institutional, proxies normally rest
with the steward or is delegated by the steward to the
investment managers.
1) Commission Costs
Brokerage Firms
2) An Analysis of actual execution price of Security
Considerations
3) Quality and timing of trade
Are expended only for brokerage and research for
the benefit of investment program, and the amount
Soft Dollars
must be reasonable in relation to the value of such
services.
Info uncovered in a qualitative review can add context
to quantitative review. Factors such as turnover, org
Qualitative review
structure, level of service, quality of reports, quality of
responses, investment education and media coverage.
Reasonable Standard of One that a reasonably prudent person would observe
Care under a given set of circumstances.
1) Prevailing economic conditions
2)Size of Client Portfolio
Factors for Frequency of 3) Investment Strategies employed.
Reviews 4) The Investment objectives
5) Volatility of the investments selected
6) Fiduciary or the regulatory obligations to client.
Investment Monitor Quarterly
Minimum
Should not be based soley on performance. What
The Decision to Switch a
matters is having confidence that the investment will
Fund
meet expectations going forward.