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Example 4 (Supervising Trading Activities and Record Keeping): Samantha Tabbing is senior vice president and portfolio manager for Crozet, Inc., a registered investment advisory and registered broker/dealer firm. She reports to Charles Henry, the president of Crozet. Crozet serves as the investment adviser and principal underwriter for ABC and XYZ public mutual funds. The two funds’ prospectuses allow Crozet to trade financial futures for the funds for the limited purpose of hedging against market risks. Henry, extremely impressed by Tabbing’s performance in the past two years, directs Tabbing to act as portfolio manager for the funds. For the benefit of its employees, Crozet has also organized the Crozet Employee Profit-Sharing Plan (CEPSP), a defined-contribution retirement plan. Henry
assigns Tabbing to manage 20 percent of the assets of CEPSP. Tabbing’s investment objective for her portion of CEPSP’s assets is aggressive growth. Unbeknownst to Henry, Tabbing frequently places S& 500 Index purchase and sale orders for the funds and the CEPSP without providing the futures commission merchants (FCMs) who take the orders with any prior or simultaneous designation of the account for which the trade has been placed. Frequently, neither Tabbing nor anyone else at Crozet completes an internal trade ticket to record the time an order was placed or the specific account for which the order was intended. FCMs often designate a specific account only after the trade, when Tabbing provides such designation. Crozet has no written operating procedures or compliance manual concerning its futures trading, and its compliance department does not review such trading. After observing the market’s movement, Tabbing assigns to CEPSP the S& 500 positions with more-favorable execution prices and assigns positions with less-favorable execution prices to the funds.
请问tabbing 在为标普500指数下订单时没有提供期货经纪人他们的帐户到底违反了什么规定啊,为什么他的交易需要被监督呢,难道是之前客户要求期货交易仅限于套期保值么,TABBING到底作错了什么
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