b. Consider the appropriateness and suitability of investment recommendations or actions for each portfolio or client (including the needs and circumstances of the portfolio or client, the basic characteristics of the investment involved, and the basic characteristics of the total portfolio).

　　c. Distinguish between facts and opinions in presenting recommendations.

　　d. Disclose to clients and prospects the basic format and general principles of the investment processes by which securities are selected and portfolios are constructed and shall promptly disclose to clients and prospects any changes that might significantly affect those processes.

　　Compliance: Know basic nature of your client; know objectives and constraints.

　　IV(B.3) Fair Dealing: Members shall deal fairly and objectively with all clients and prospects when disseminating investment recommendations, disseminating material changes in prior investment recommendations, and taking investment action.

　　Compliance:

　　1. Limit the number of people privy to recommendations and changes.

　　2. Shorten the time frame between initiation and dissemination.

　　3. Publish personnel guidelines for pre-dissemination.

　　4. Simultaneous dissemination.

　　5. Establish rules about employee trading activities.

　　6. Establish procedures for determining material changes.

　　7. Maintain a list of clients and their holdings.

　　8. Develop trade allocation procedures.

　　9. Make sure one account is not being used to bail out other accounts.

　　10.If the firm offers differing levels of service, this fact should be disclosed to all clients.

　　IV(B.4) Priority of Transactions: Clients and employers shall have priority over transactions in securities or other investments of which a member is the beneficial owner so that such personal transactions do not operate adversely to their clients' or employer's interests. If members make a recommendation regarding the purchase or sale of a security or other investment, they shall give their clients and employer adequate opportunity to act on the recommendation before acting on their own behalf.

　　Compliance:

　　1. Define personal transactions.

　　2. Define covered investments.