trading policy & practice.

Core Planning uses the electronic order entry system provided by a third party custodian to enter and execute trading activity and transactions.


Directed Brokerage
We do not allow clients to direct brokerage. We will recommend one or more custodians or broker-dealers to effect securities transactions for our clients. The custodians or broker-dealers were chosen based on our fiduciary responsibilities to provide best execution.


Soft Dollar Arrangements Statement
“Soft dollar” practices are defined as arrangements under which products or services, other than execution of securities transactions, are obtained by an investment adviser from or through a broker-dealer in exchange for the direction by the adviser of client brokerage transactions to the broker-dealer. In the event of soft dollar arrangements, we have an obligation to act in the best interests of our clients and to place client interests before our own. We also has an affirmative duty of full and fair disclosure of material facts in relation to soft dollar arrangements to its clients.

Firm Statement

Core Planning does not employ any soft dollar arrangements.

Compliance Requirements

Core Planning’s CCO is responsible for the following:

  • Ensuring that this statement is followed, and if any soft dollar arrangements are created, that the statement as well as the firm’s ADV Form 2A are promptly updated to properly reflect this;

  • Making sure that the firm receives an annual soft dollar statement from any broker- dealer with which the firm may have a future soft dollar arrangement;

  • Keeping statements of any products and/or services received for soft dollars;

  • Ensuring the best execution of securities transactions when they arrange for or execute trades on behalf of clients and customers; and

  • Maintaining adequate books and records concerning allocation of mixed use items.

Review Process

Reviews of the firm’s soft dollar arrangements are conducted by the CCO on an annual basis at a minimum. Interim reviews may be conducted in response to changes in the firm’s soft dollar arrangements.

Block Trading

Should we decide that aggregating client orders (block trading) for more than one client is in the best interests of those clients, we will effect the transaction and allocate shares from the block trade in a fair and equitable manner.

We will follow custodial or broker-dealer instructions for a block trade, including but not limited to:

  • Indicating the number of shares to be allocated to each account;

  • Distributing custodian or broker-dealer charges for the block trade on a pro-rata basis to each client account (generally there are no trading fees); and

  • Ensuring each account receives the average execution price of the trade(s).

While block trading may benefit clients by purchasing or selling larger blocks in groups, we do not feel that the clients are at a disadvantage due to the best execution practices of its custodian. Under certain circumstances, even though we maintain the ability to block trade, we may not choose this method of transaction.

Circumstances when block trading will not be used:

  • The size of the order in dollars may affect the market in the security;

  • The volume of the order in shares may affect the market in the security;

  • The number of client accounts involved in the order;

  • Models and strategies of the firm affect the custom component of a client’s account

Under certain circumstances, employees of Core Planning may participate in the aggregated trade of securities alongside clients. This will be covered in the Code of Ethics section of the manual. Employees will not be favored as far as price or allocations in this type of transaction are concerned.

Records associated with block trades will be kept by the firm as part of its books and records requirements.

Trade Errors
A trade error occurs when there is a deviation from the general trading practices involving transactions and settlements of trades for a client’s account.

Part of our fiduciary obligation is to identify and correct these errors as soon as discovered.

In general, the following may be viewed as trade errors:

  • An incorrect type of transaction (e.g., buy, sell, limit, market);

  • A purchase or sale of the wrong security or the wrong amount;

  • A trade taking place in an incorrect account number;

  • An inaccurately allocated block trade

  • The purchase or sale of securities in violation of the client’s investment profile or guidelines; and

  • The purchase or sale of securities for non-discretionary clients prior to or without receiving client consent, or without proper documented authorization.


The following types of errors will not be deemed a trade error:

  • An incorrect trade that was caught prior to settlement thereby not having a negative impact on the client;

  • A trade that was improperly documented;

  • The rewriting of a ticket that describes or corrects an improperly executed transaction;

  • An error made by an unaffiliated third party (broker-dealer, custodian, etc.). However, we are responsible for reviewing these trades and ensuring that third party errors are favorably resolved; and

  • A good faith transaction for the client, based on our evaluation and assessment, which may not be in line with client’s objective.


Trade errors must be brought to the CCO in a timely manner once discovered.

The CCO should document when the trade error occurred and whether the firm is responsible. If responsible, we will look to correct the error immediately, on the same day if possible, following fiduciary standards and acting in the client’s best interest. If a third party is responsible, we will oversee the resolution.

Any loss will be reimbursed to the client for the full amount of the loss, including the reimbursement of any transaction fees, in the form of a statement credit or check written by Core Planning, if the custodian or broker-dealer does not cover it.


We may also contact our E&O carrier if needed.

If there is a profit resulting from the error, we may elect to allow the client to retain the profit.

Payments made to clients will be properly documented. The CCO will maintain a trade error file for a period of at least five years.

Trading Practices

Approved Custodian Selection

The following steps will be taken when selecting a custodian to execute client trades:

  • The CCO will create a list of custodians approved to execute client trades

  • The CCO will periodically and systematically monitor and evaluate the execution and performance capabilities of the custodians.

  • The CCO will request periodically and review some or all of each custodian(s) reports on order execution (SEC Rule 11Ac1-5) and order routing (SEC Rule 11Ac1-6) to ascertain whether the executing custodian(s) is routing client trades to market centers that execute orders at prices equal to or superior to those available at other market centers. Evidence of such reviews shall be appropriately documented.

Best Execution

Under applicable law, we owe a fiduciary duty to clients to obtain best execution of their brokerage transactions.

We also have a fiduciary duty to our clients to achieve best execution when we place trades with custodians. Failure to fulfill this duty to clients to obtain best execution may have significant regulatory consequences.

Our policies are modeled after the guidelines articulated by the regulators; specifically, we believe that, to a significant degree, best execution is a qualitative concept. In deciding what constitutes best execution, the determinate factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution.

In making this determination, our policy is to consider the full range of the custodian's services, including without limitation, the value of research provided, execution capabilities, commission rate, financial responsibility, administrative resources and responsiveness.

We will periodically and systematically, but no less than annually, evaluate the quality of brokerage services provided by custodians executing transactions.


Factors that will be considered will include:

  • Quality of overall execution services provided;

  • Promptness of execution;

  • Liquidity of the market for the security in question;

  • Provision of dedicated telephone lines;

  • Creditworthiness, business reputation, and reliability of the broker-dealer;

  • Promptness and accuracy of oral, hard copy or electronic reports of execution and confirmation statements;

  • Ability and willingness to correct trade errors;

  • Ability to access various market centers, including the market where the security trades;

  • The custodian's facilities, including any software or hardware provided to the adviser;

  • Commission rates, fees, and other costs

 Anti-Insider Trading Policy

Background

An investment adviser should establish, maintain and enforce written policies and procedures reasonably designed, taking into consideration the nature of such investment adviser’s business, to prevent the misuse of material, non-public information by such investment adviser or any person associated with such investment adviser.

Compliance Requirements

The CCO is responsible for:

  • Ensuring employees and associated persons sign a statement acknowledging and agreeing to abide by the firm’s prohibition on insider trading;

  • Maintaining a list for each access person listing securities owned (“Holdings report” – see Sample 8);

  • Maintaining copies of transaction confirmations or monthly or quarterly securities account statement summaries from each of these persons. See Sample 9 for a sample Transactions report;

  • Reviewing these confirmations and statements for inappropriate transactions and reporting them to CCO for action;

  • Maintaining records of CCO reviews and results.

The employee acknowledgement statement and Holdings report should be provided to the CCO on the date of association and annually thereafter. Other record-keeping requirements should be done on a quarterly basis, no more than 10 days after the end of the calendar quarter. Reviews of this policy are to be conducted by the CCO on an annual basis at a minimum.

Material Interest of the Adviser and Personal Trading Activities of Supervised Person

Material Interest

Core Planning will not recommend to clients, or buy or sell for client accounts, securities in which the firm or a related person has a material financial interest. (Examples of a material financial interest would include: acting as a principal, general partner of a partnership/fund where clients are solicited to invest, or acting as an investment adviser to an investment company that the firm recommends to clients.)

Investing Personal Money in the Same Securities as Clients

From time to time, employees of Core Planning may buy or sell securities for themselves that they also recommend to clients. The CCO will document any transactions that could be construed as conflicts of interest and we will always transact client business before our own when similar securities are being bought or sold.