How to determine if an investment decision or investment proposal is suitable for clients?

作出投資決策或投資建議前，評估是否適合客戶。

評估整個投資組合是否適合客戶。

When responsible for managing a portfolio to a specific mandate, strategy, or style, must only make investment recommendations or take investment actions that are consistent with the stated objectives and constraints of the portfolio. （如果投資前對投資目標及限制進行過約定，投資決策或投資建議要嚴格遵守該約定）

If trade is known unsuitable: To individual, should refrain from trade or seek an affirmative statement from the client that suitability is not a consideration. （客戶提出了交易是unsuitable的，如果客戶堅持，要取得客戶的書面同意）

Investment policy statement (IPS)

Information includes the client’s financial circumstances, personal data (such as age and occupation) that are relevant to investment decisions, attitudes toward risk, and objectives in investing. More important, IPS should includes risk tolerance, return requirements, and all investment constraints.

Updating the IPS should be repeated at least annually and also prior to material changes to any specific investment recommendations. （IPS必須每年更新，如果投資有實質性變化，需要先更新IPS）

Annual review is reasonable unless business or other reasons, such as a major change in market conditions, dictate more frequent review.

An investment with high relative risk may be a suitable in the context of the entire portfolio or when the client’s stated objectives contemplate speculative or risky investments.

Responsibility is to invest in a manner consistent with the stated mandate. Those who manage pooled assets to a specific mandate are not responsible for any individual investor. （管理資產組的，無需對個人客戶負責）Only those who have advisory relationship are responsible for individual clients.