Form Sec 1707 - Uniform Application For Investment Adviser Registration - Securities And Exchange Commission Page 41
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49FORM ADV
Applicant:
SEC File Number:
Date:
Part II - Page 6
801-
12.
Investment or Brokerage Discretion.
A.
Does applicant or any related person have authority to determine, without obtaining specific client consent, the:
Yes
No
(1) securities to be bought or sold? ..................................................................................................................
Yes
No
(2) amount of the securities to be bought or sold? ...........................................................................................
Yes
No
(3) broker or dealer to be used? .......................................................................................................................
Yes
No
(4) commission rates paid? ..............................................................................................................................
Yes
No
B.
Does applicant or a related person suggest brokers to clients? ...........................................................................
For each yes answer to A describe on Schedule F any limitations on the authority. For each yes to A(3), A(4)
or B, describe on Schedule F the factors considered in selecting brokers and determining the reasonableness
of their commissions. If the value of products, research and services given to the applicant or a related
person is a factor, describe:
•
the products, research and services
•
whether clients may pay commissions higher than those obtainable from other brokers in return for those products and
services
•
whether research is used to service all of applicant's accounts or just those accounts paying for it; and
•
any procedures the applicant used during the last fiscal year to direct client transactions to a particular broker in return
for product and research services received.
13.
Additional Compensation.
Does the applicant or a related person have any arrangements, oral or in writing, where it:
A.
is paid cash by or receives some economic benefit (including commissions, equipment or non-research
Yes
No
services) from a non-client in connection with giving advice to clients? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Yes
No
B.
directly or indirectly compensates any person for client referrals?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(For each yes, describe the arrangements on Schedule F.)
Balance Sheet. Applicant must provide a balance sheet for the most recent fiscal year on Schedule G if applicant:
14.
•
has custody of client funds or securities (unless applicant is registered or registering only with the
Securities and Exchange Commission); or
•
requires prepayment of more than $500 in fees per client and 6 or more months in advance
Yes
No
Has applicant provided a Schedule G balance sheet? ..............................................................................
Answer all items. Complete amended pages in full, circle amended items and file with execution page (page 1).
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