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- 2011-7-11
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- 2013-6-27
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Alba Vasquez allocates trades of hot new IPOs as follows: m×p/(p+s) shares to performance-based fee accounts, m×s/(p+s) shares to standard fee accounts, where there are p suitable performance based fee accounts, s suitable standard fee accounts, and m shares available. This action is: A)
| not permissible since it effectively favors the performance-based fee accounts. |
| B)
| not permissible since it is based upon a formula that is not inherently fair. |
| C)
| permissible since it effectively amounts to a strict pro rata basis of allocation. |
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The formula shown above is nothing more than a simple pro rata basis of allocation (assuming that the shares are then subsequently allocated in the same fashion over all of the sub accounts by category). Hence, this is permissible. |
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