TRADE AGGREGATION, ALLOCATION AND IPOS ON THE SEC'S RADAR SCREEN Available to Purchase

One current and long‐term blip on the Securities and Exchange Commission's (SEC) radar screen is trade allocation, including the allocation of initial public offerings (IPOs). In the May 1, 2000 “Dear Registered Investment Adviser Letter,” the SEC's Office of Compliance Inspections and Examinations (OCIE) summarized select areas reviewed, and violations of the Investment Advisers Act of 1940 (Advisers Act) found during compliance examinations of investment advisers. Item II of the letter addressed trade allocations and more specifically, allocations of IPOs. The letter described three examples of how an adviser could defraud clients by allocating trades inequitably among clients, including the following example addressing IPOs: