Fair trade allocation is a critical aspect of investment advisory practices, ensuring all clients are treated equitably. However, improper trade allocation—such as "cherry-picking," where profitable trades are unfairly assigned to preferred accounts—can lead to regulatory scrutiny, financial penalties, and reputational damage.

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A recent SEC enforcement action against Western Asset Management Company (WAMCO) highlights the risks of trade allocation misconduct and underscores the need for firms to establish strong policies to prevent such issues. In an article for Corporate Compliance Insights, Howard Scheck and Chris Hoyle share risk mitigation tips, including:

  • Fiduciary Duty: Ensuring all clients receive fair treatment in trade allocations.
  • Preventing Conflicts of Interest: Implementing safeguards to eliminate favoritism or self-dealing.
  • Regulatory Compliance: Aligning practices with SEC guidelines to maintain transparency and accountability.

To build an effective trade allocation framework, firms should establish clear allocation criteria, segregate duties to prevent conflicts, enforce robust approval processes, maintain thorough documentation, and conduct regular compliance reviews. As regulatory expectations evolve, continuous assessment and refinement of these policies are essential to protecting both investors and firms from potential pitfalls.

Read the full article here.


If you have any questions or would like to discuss these topics please reach out to Chris Hoyle or Howard Scheck.

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About the Authors

Chris Hoyle

Christopher Hoyle

Chris Hoyle, a Partner with StoneTurn, has nearly 20 years of professional experience in fraud and compliance risk management and forensic accounting. Chris specializes in assessing and remediating compliance programs, […]

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Howard Scheck

Howard Scheck

Howard Scheck, a Partner with StoneTurn, is an accountant and attorney with over three decades of experience leading teams investigating a wide range of financial reporting issues. With deep expertise […]

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