Firm independence policies (GQRMM – Policy 6.3.3) prohibit covered persons on an audit client from having brokerage accounts with the audit client, unless the audit client is a bank, broker or similar institution.
Covered persons on an SEC audit client (GQRMM – Policy 20.3.4) are permitted to have brokerage accounts with SEC audit clients as long as the account balances, including cash and securities, do not exceed the insured limit (if the insurance program is not substantially equivalent to the US SIPC insurance program (e.g. Government sponsored) the account is not permitted).
Futures commission merchant accounts (including any futures, commodity, or similar account maintained with a futures commission merchant) with an SEC audit client are not permitted for covered persons.
Non-covered persons are permitted to have brokerage accounts or futures commission merchant accounts without impairing independence.
I was in compliance with firm independence policies regarding brokerage accounts during the Confirmation Period. *!
Firm independence policies (GQRMM – Policy 6.3.3) prohibit covered persons on an audit client from having brokerage accounts with the audit client, unless the audit client is a bank, broker or similar institution. Covered persons on an SEC audit client (GQRMM – Policy 20.3.4) are permitted to have brokerage accounts with SEC audit clients as long as the account balances, including cash and securities, do not exceed the insured limit (if the insurance program is not substantially equivalent to the US SIPC insurance program (e.g. Government sponsored) the account is not permitted). Futures commission merchant accounts (including any futures, commodity, or similar account maintained with a futures commission merchant) with an SEC audit client are not permitted for covered persons. Non-covered persons are permitted to have brokerage accounts or futures commission merchant accounts without impairing independence. I was in compliance with firm independence policies regarding brokerage accounts during the Confirmation Period. *!
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