Retirement Board of Allegheny County Directed Brokerage Policy (MFDV’s includign Veteran Owned)——>>>>see Page 2 – Approved List http://www.nasp-ny.org/files/pdf/RBACplacecard1017.pdf
Retirement Board of Allegheny County
www.county.allegheny.pa.us/retirement
Values
“RBAC recognizes that brokerage commissions are a significant expenditure of the fund and is committed to using all segments of the financial community for broker/dealer transactions of the pension fund and wishes to direct certain of its trades to local, minority/women owned brokerage firms in a manner consistent with its fiduciary responsibilities.”
Definitions
Broker/Dealers: Firms which customarily perform trades for an institutional clientele. Such brokers may trade on the floor of the various national and regional stock exchanges, or may trade in the third and fourth markets performing transactions outside of the securities exchanges. Brokers should be members in good standing with the Financial Industry Regulatory Authority (FINRA).
Best Execution: Investment managers shall define (in writing for the RBAC) their method of utilizing professional judgment in the selection of brokers and the commissions paid.
Minority/Women-Owned: Owners who are citizens of the United States (or lawfully admitted permanent residents) who are Black Americans, Hispanic Americans, Native Americans, Asian-Pacific Americans, Subcontinent Asian Americans, women or others found to be socially and economically
disadvantaged.
Local: Brokers/Dealers headquartered in the Commonwealth of PA.
Policies & Procedures
It is the policy of the RBAC that its investment managers shall use their best efforts to allocate trades on an annual basis as detailed below, or in such other manner
as the RBAC may communicate in writing to the investment manager, provided that all trades are consistent with the principles of best execution.
• Investment managers objectively evaluate all qualified broker/dealers regardless of location, race, gender or handicap.
• Local, minority/women owned brokerage firms should be included in the investment managers’ selection process.
• Managers define in writing for the RBAC the criteria and process for selecting qualified broker/dealers.
• The RBAC shall not subsidize the managers’ other accounts under management at the expense of higher trading costs to the RBAC.
• At least twenty-five percent (25%) of securities trading brokerage commissions shall be paid to local brokerage firms.
• In addition to the target set forth above, at least twenty-five percent (25%) of securities trading brokerage commissions shall be paid to minority/women owned brokerage firms.
• The questionnaire is posted on the RBAC website and brokers/dealers can apply at any time.
• Firms below 20 million trades annually and above 2 billion trades annually are excluded.
• Questionnaire, certification and selection process documents must be in the possession of RBAC.
• Emerging Manager Consultant will notify applicable broker/dealers of the changes to RBAC’s approved broker listing.
• If investment managers in certain classes have more difficulty complying with policy, the Governance Committee may lower those targets.
• Emerging Manager Consultant will notify investment managers with the policy requiring signed acceptance.
• Veteran-owned broker/dealers are desired, but not directed.
• Compliance with the trading policy will be considered as part of the manager’s overall performance. As such, non-compliance may cause a manager
to be placed on watch list status. Continued non-compliance may result in the termination of the manager.
• This policy will be reviewed annually by the RBAC.
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