Sam,
Great questions. I worked for brokerage years ago. Had some constraints, but not as tough or stringent as yours. UGH. (But understand why firms have rules.) These constraints are a REAL quandary. Is that 20 calendar days or 20 business days? Can you ask management if you can have your account structured so you do not own stocks your clients own? I know they want NO conflict of interest. I respect that. Can you ask if you can invest in stocks your customers don't own or haven't bought in 2 weeks? The problem with that idea is if they own AAPL, GOOGL etc you're locked out of them. Can you structure the trade entry so they get filled first and you second? (with the stipulation you will not front run them either buying or selling?) Sam, I racking my brains about this. It really puts you in a tough spot. And we do NOT want an issue with compliance! I would approach your manager with these ideas and see what they say. After you get an answer, please get back with me. Have a great weekend! I respect your moral integrity!
Sincerely
Pat
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