Common use of Brokerage Practices Clause in Contracts

Brokerage Practices. As described under Item 4 of this Brochure, titled Advisory Business, Confluence offers portfolio management services on either a “discretionary” or a “non-discretionary” basis. In a discretionary account (typically referred to as an SMA), at the outset of the contractual relationship, Confluence is granted the authority by a client to determine the securities or other assets to purchase or sell in the account. This discretion will remain in effect unless revoked by the client or their Financial Advisor (on client’s behalf). Confluence will monitor the SMA and will purchase and sell securities and other assets in the account consistent with the investment strategy or strategies selected by the client or the Financial Advisor (on client’s behalf) as part of the overall investment plan (subject to any reasonable restrictions provided in writing to Confluence). In a non-discretionary account, Confluence makes recommendations to the Financial Advisor or Financial Institution concerning securities and other assets, but Confluence does not have the authority to implement such recommendations. Rather, the Financial Advisor or Financial Institution (on clients’ behalf) have the sole authority to determine whether securities or other assets in the account are purchased or sold in accordance with the Confluence recommendations and to determine the Financial Institutions through which such transactions are implemented. Accordingly, Confluence is not involved in the selection of the Financial Institutions through which transactions are implemented. Non-discretionary accounts also include those for which Confluence supervises the securities or other assets in the account, without any discretionary authority.

Brokerage Practices. As described under Item 4 of this Brochure, titled Advisory Business, Confluence offers portfolio management services on either a “discretionary” or a “non-discretionary” basis. In a discretionary account (typically referred to as an SMA), at the outset of the contractual relationship, Confluence is granted the authority by a client to determine the securities or other assets to purchase or sell in the account. This discretion will remain in effect unless revoked by the client or their Financial Advisor (on client’s behalf). Confluence will monitor the SMA and will purchase and sell securities and other assets in the account consistent with the investment strategy or strategies selected by the client or the Financial Advisor (on client’s behalf) as part of the overall investment plan (subject to any reasonable restrictions provided in writing to Confluence). In a non-discretionary account, Confluence makes recommendations to the Financial Advisor or Financial Institution concerning securities and other assets, but Confluence does not have the authority to implement such recommendations. Rather, the Financial Advisor or Financial Institution (on clients’ client’s behalf) have the sole authority to determine whether securities or other assets in the account are purchased or sold in accordance with the Confluence recommendations and to determine the Financial Institutions through which such transactions are implemented. Accordingly, Confluence is not involved in the selection of the Financial Institutions through which transactions are implemented. Non-discretionary accounts also include those for which Confluence supervises the securities or other assets in the account, account without any discretionary authority.