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Actual exam question for CIRO's CIRE exam Question #: 94 Topic #: 1
A client has an account with their Investment Dealer. The dealer acts as principal in a trade for them at a price that is not as good as the prevailing market price. How would this trade be considered?
The correct answer is C . An Investment Dealer's decision to act as principal -trading from its own inventory against the client's order-does not eliminate its obligation to pursue the most advantageous execution terms reasonably available for the client. CIRO's best-execution framework defines best execution by reference to the overall execution terms reasonably available, with relevant factors including price, transaction costs, speed and certainty of execution. Client-principal trading involves additional conflict considerations. Under UMIR 8.1, specified client- principal transactions require the Dealer to take reasonable steps to ensure the price represents the best available price under prevailing market conditions ; for covered smaller orders, the client must receive price improvement relative to the marketplace. CIRO's policy explains that where the Dealer sells to its client, the client should pay less than the best ask in the circumstances covered by the rule. Therefore, deliberately giving the client a price inferior to reasonably available market terms is inconsistent with the best-execution obligation. A is unrelated because no margin deficiency is described. B reverses the regulatory principle: principal capacity does not excuse inferior execution. D requires additional elements of manipulative or deceptive market conduct; an unfavourable principal price alone does not establish market manipulation. Study Guide Reference: CIRE Element 6.1 - Best Execution and client-principal trading; IDPC Rule 3100 Part C and UMIR 8.1.
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