Description Of A M Investment Management Staff - 1436 Words

MEMORANDUM To: AM Investment Management Staff From: Bill Post, Chief Compliance Officer Co-National Practice Leader | AM Investment Management, LLC â€Å"AMIM† Subject: AMIM Best Execution Policy Date: August 24th, 2016 Introduction The U.S. Securities and Exchange Commission (â€Å"Commission†) position is that as a registered investment adviser under the U.S. Investment Advisers Act of 1940 should adopt written policies and procedures designed reasonably to ensure that the adviser satisfies the best execution for client trades. The characteristics of the CD market presents AM Investment Management (AMIM) with practical difficulties in assessing and documenting CD best execution not faced when undertaking, for example, equity transactions. Unlike their equity counterparts, the Certificate of Deposit (CD) market is fragmented and often subject to limited transparency as a result of the absence of a centralized market or formal exchange. CDs are traded Over-the-counter (OTC), via a dealer network, as opposed to on a centralized exchange. This memo will state AMIM best execution policies and procedures tailored to AMIM’s operations and the types of fixed-income instruments (CDs) in which it trades. This processes and procedures will create a systematic, repeatable, adaptable, and demonstrable approach to seeking best execution on an overall basis. Background Under a well-settled principle of law, AMIM is a fiduciary subject to a number of specific obligations when acting onShow MoreRelatedThe Development Of Tourism And Hospitality Industry1410 Words   |  6 Pagesindustry. Therefore, talented human resource management is important to hospitality industry. However, the quantity of jobs is unquestionable the quality of many of these jobs is of great concern to academics and policymakers alike (Nickson, D., 2013). 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