PERACApproval |
Regulation Number |
Investment Regulation/Supplemental Regulation |
04/10/2003 |
17.04 (6) |
The Braintree Retirement Board may enter into a contract with Eubel Brady & Suttman Asset Management and the trading activities of that firm shall not be construed as violating Investment Regulation 17.04 (6). While there may be some instances where some trades executed on behalf of the Board do not have priority over those executed for the firm’s interests, there will be no instances where the firm’s interests have priority over those of the Board. The requirement that the Board be given adequate opportunity to act on a recommendation by the manager before the firm acts on its own behalf is of limited practicality since the Board will be giving the manager discretionary authority to execute trades based on their professional judgment. In summary, the Board sees no substantial basis to question whether EBS will be in violation of the fundamental requirement that “personal transactions do not operate adversely to the board’s interest.” |