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Reading Reading 3: CFA Institute Soft Dollar Standards LOS b-Q 1~5

1William Nagle, CFA has his own money management firm. He has a wide range of clients. Some of his clients are entirely invested in the money market while others like to actively trade stocks including hot new issues and options.

Over the years Nagle has developed a good relationship with Presley Brothers Brokerage who executes his trades. One of the reasons Nagle initially chose and continues to use Presley Brothers is that Presley Brothers provides to Nagle a free high-speed Internet service plus the services of a top-rated research firm over the Internet. That service provides up-to-the minute recommendations. Although the fees Presley Brothers charges Nagle’s clients per trade are slightly higher than competing firms, Nagle feels their speed of execution is worth the cost. Nagle has found the recommendations from the Internet research firm have been useful for some of his more active clients.

Presley Brothers also underwrites stocks and gives Nagle the opportunity to buy shares in initial public offerings for his clients. The amount of IPO stock offered to Nagle is proportional to the amount of commissions that Nagle has generated. As a rule, Nagle allocates the IPO shares to the clients who generated the most commissions in the previous year. He discloses this practice to all his clients, and since Nagle started dealing with Presley Brothers Brokerage, all of the IPOs Presley Brothers has underwritten have made a profit for Nagle’s clients. Therefore, Nagle has a standing order with Presley Brothers to purchase as much of each IPO that Presley Brothers can give him. Once Nagle gets the IPO issue, he divides it into three allocations and begins calling his clients one at a time, beginning with the top commission-generating client, and offers to sell an allocation to each client until all three allocations are sold.

Presley Brothers also offers Nagle another perk for doing business with the firm. If Nagle generates a certain minimum in commissions, then Presley Brothers provides Nagle with the opportunity to offer discount commissions on option trades. In addition to that, exceeding the commission quota earns Nagle an all-paid weekend trip to a resort where Presley Brothers gives seminars to managers like Nagle who have exceeded the commission quota. The trip does include seminars that provide valuable information on the products like mutual funds that Presley Brothers offers and financial markets in general, but it also takes place at a posh resort with many free amenities. In recent years, Nagle has exceeded the commission quota and has been able to take the trip. His main focus on the trips has been to learn something at the seminars that he can offer to his larger clients who generate the most business. The trips have given Nagle sufficient information on Presley Brothers’ products so that Nagle has decided to satisfy all of his clients’ needs with Presley Brothers products.

By choosing to use Presley Brothers Brokerage for the indicated reason, has Nagle broken the standard concerning soft dollars?

A)   Yes, because his clients pay higher fees and he gets free Internet service only.

B)   Yes, because his clients pay higher fees and he gets the services of the research firm only.

C)   Yes, because his clients pay higher fees and he gets free Internet service and the services of a research firm.

D)   No, because although his clients pay higher fees, the services are worth it.

2The method that Nagle uses to allocate the IPO issues to his clients is:

A)   a violation of the standard on soft dollars.

B)   not a violation of the standards because Nagle discloses the practice to his clients.

C)   a violation of the standards on fair dealing.

D)   not a violation of the standards because it uses an acceptable ad hoc method.

 

3Nagle’s standing order to purchase as much as much as possible of each Presley Brothers’ IPOs is a violation of the standard because:

A)   Nagle should get advanced notice of his clients’ interest in the IPO.

B)   Nagle is, in effect, distributing soft dollars.

C)   Nagle gets the IPO stock from the firm that executes his trades for him.

D)   of no reason, it is actually an acceptable practice because all the IPOs have been profitable.

4Nagle has violated the standards on research objectivity by:

A)   his standing order for IPOs but not by his using only Presley Brothers investment products.

B)   his only using Presley Brothers investment products but not by his standing order for IPOs.

C)   neither his standing order for IPOs nor his only using Presley Brothers investment products.

D)   his standing order for IPOs and his using only Presley Brothers investment products.

5With respect to the trip that Nagle has been taking each year Nagle:

A)   should disclose it to his clients because it provides him with information about stock market activities other than those of Presley Brothers.

B)   should disclose it to his clients because it could represent a conflict of interest and hinder his objectivity.

C)   does not need to disclose it to his clients because it provides him with valuable information.

D)   should not disclose it to his clients because that might influence the amount of business the clients decide to do with him.

答案和详解如下:

1William Nagle, CFA has his own money management firm. He has a wide range of clients. Some of his clients are entirely invested in the money market while others like to actively trade stocks including hot new issues and options.

Over the years Nagle has developed a good relationship with Presley Brothers Brokerage who executes his trades. One of the reasons Nagle initially chose and continues to use Presley Brothers is that Presley Brothers provides to Nagle a free high-speed Internet service plus the services of a top-rated research firm over the Internet. That service provides up-to-the minute recommendations. Although the fees Presley Brothers charges Nagle’s clients per trade are slightly higher than competing firms, Nagle feels their speed of execution is worth the cost. Nagle has found the recommendations from the Internet research firm have been useful for some of his more active clients.

Presley Brothers also underwrites stocks and gives Nagle the opportunity to buy shares in initial public offerings for his clients. The amount of IPO stock offered to Nagle is proportional to the amount of commissions that Nagle has generated. As a rule, Nagle allocates the IPO shares to the clients who generated the most commissions in the previous year. He discloses this practice to all his clients, and since Nagle started dealing with Presley Brothers Brokerage, all of the IPOs Presley Brothers has underwritten have made a profit for Nagle’s clients. Therefore, Nagle has a standing order with Presley Brothers to purchase as much of each IPO that Presley Brothers can give him. Once Nagle gets the IPO issue, he divides it into three allocations and begins calling his clients one at a time, beginning with the top commission-generating client, and offers to sell an allocation to each client until all three allocations are sold.

Presley Brothers also offers Nagle another perk for doing business with the firm. If Nagle generates a certain minimum in commissions, then Presley Brothers provides Nagle with the opportunity to offer discount commissions on option trades. In addition to that, exceeding the commission quota earns Nagle an all-paid weekend trip to a resort where Presley Brothers gives seminars to managers like Nagle who have exceeded the commission quota. The trip does include seminars that provide valuable information on the products like mutual funds that Presley Brothers offers and financial markets in general, but it also takes place at a posh resort with many free amenities. In recent years, Nagle has exceeded the commission quota and has been able to take the trip. His main focus on the trips has been to learn something at the seminars that he can offer to his larger clients who generate the most business. The trips have given Nagle sufficient information on Presley Brothers’ products so that Nagle has decided to satisfy all of his clients’ needs with Presley Brothers products.

By choosing to use Presley Brothers Brokerage for the indicated reason, has Nagle broken the standard concerning soft dollars?

A)   Yes, because his clients pay higher fees and he gets free Internet service only.

B)   Yes, because his clients pay higher fees and he gets the services of the research firm only.

C)   Yes, because his clients pay higher fees and he gets free Internet service and the services of a research firm.

D)   No, because although his clients pay higher fees, the services are worth it.

The correct answer was C)    

Nagle is receiving free Internet service, and does not pass the savings on to his clients. The research benefits some of the clients; therefore, there must be some clients paying a higher fee and not getting anything from Nagle or Presley Brothers for the extra expense.

2The method that Nagle uses to allocate the IPO issues to his clients is:

A)   a violation of the standard on soft dollars.

B)   not a violation of the standards because Nagle discloses the practice to his clients.

C)   a violation of the standards on fair dealing.

D)   not a violation of the standards because it uses an acceptable ad hoc method.

 

The correct answer was C)    

Nagle needs to give all of his clients an opportunity to participate in profitable deals. In Nagle’s current system, it is possible for long-time clients who generate a consistent level of business per year to never be able to participate in a profitable IPO.

3Nagle’s standing order to purchase as much as much as possible of each Presley Brothers’ IPOs is a violation of the standard because:

A)   Nagle should get advanced notice of his clients’ interest in the IPO.

B)   Nagle is, in effect, distributing soft dollars.

C)   Nagle gets the IPO stock from the firm that executes his trades for him.

D)   of no reason, it is actually an acceptable practice because all the IPOs have been profitable.

The correct answer was A)

The standard on Trade Allocation: Fair Dealing and Disclosure requires that Nagle get an advanced indication of client interest.

4Nagle has violated the standards on research objectivity by:

A)   his standing order for IPOs but not by his using only Presley Brothers investment products.

B)   his only using Presley Brothers investment products but not by his standing order for IPOs.

C)   neither his standing order for IPOs nor his only using Presley Brothers investment products.

D)   his standing order for IPOs and his using only Presley Brothers investment products.

The correct answer was D)

Nagle is not doing any research on the IPOs before taking the allocations. Apparently, taking the trips has led to Nagle limiting his choices of possible products for his clients. Nagle needs to be more thorough in researching the needs of his clients.

5With respect to the trip that Nagle has been taking each year Nagle:

A)   should disclose it to his clients because it provides him with information about stock market activities other than those of Presley Brothers.

B)   should disclose it to his clients because it could represent a conflict of interest and hinder his objectivity.

C)   does not need to disclose it to his clients because it provides him with valuable information.

D)   should not disclose it to his clients because that might influence the amount of business the clients decide to do with him.

The correct answer was B)

Nagle’s objectivity has clearly been compromised since he has started only using Presley Brothers’ products. The clients need to be aware that a significant portion of Nagle’s information is coming from the one firm that executes his trades and provides all of his clients’ products.

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