Every registered investment adviser has a duty to provide “best execution” on all
securities transactions for their clients. This duty is not specifically set forth in any particular
statute, but rather, arises from the adviser’s fiduciary obligation to exercise reasonable care to
obtain the most favorable terms for its clients. The Securities and Exchange Commission (“SEC”
or the “Commission”) has defined this duty as the requirement that an adviser “execute securities
transactions for clients in such a manner that the client’s total cost or proceeds in each
transaction is most favorable under the circumstances.”
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