MONITORING BEST EXECUTION FROM AN INVESTMENT ADVISER'S PERSPECTIVE

The obligation to seek best execution on behalf of clients is not a new issue for investment advisers but one which has received increased scrutiny by the SEC's Office of Compliance Inspections and Examinations (OCIE). This article discusses an adviser's duty to seek best execution and offers suggested guidelines from regulators and industry advocates when developing and implementing best execution policies and procedures. It also illustrates different trading analyses and sample controls that advisers may wish to consider when establishing a best execution monitoring program.