Regulation Best Interest


Regulation BI (“RegBI”) is a new rule under the Securities Exchange Act of 1934 (“Exchange Act”) that establishes a “best interest” standard of conduct for broker-dealers and their associated financial professionals when making a recommendation of any securities transaction or investment strategy involving securities to a retail customer. This means that when JKR & Company (“JKR”) provides a recommendation to buy, sell, hold, exchange, or transfer an investment, we must place your interest ahead of ours.

Acting in your best interest means we must (1) disclose to you the scope and terms of our relationship with you, (2) exercise reasonable diligence, care, and skill in making the recommendation, (3) identify, eliminate or mitigate, and disclose those conflicts of interest that might incline us to consciously or unconsciously make a recommendation that is not disinterested, and (4) establish a compliance program that is reasonably designed to achieve compliance with Regulation BI.

Our Disclosure Obligation

We are committed to helping our retail customers understand the (1) capacity in which we act when making a recommendation, (2) fees and costs that apply to your transactions, holdings, and accounts, (3) services that are available to you including any material limitations or other facts, and (4) material facts or conflicts of interest related to a recommendation so that you can make an informed decision whether you want to proceed with the transaction. To achieve this, we have created several additional written disclosure documents including:

  1. • Form CRS
  2. • Brokerage and Advisory Relationships: Understanding the Difference
  3. • JKR Brokerage Compensation and Conflicts of Interest
  4. • JKR Schedule of Fees

Additionally, you will receive or have access to other written disclosure documents that accompany the recommendation we make to you. These documents are prepared by a third-party such as your custodian or the product sponsor and include account agreements, prospectuses, or memorandums, among others.

Finally, financial representatives will make every effort to make certain you understand the costs and value of the solution that he or she recommends to you.

Please take the time to read all of the written disclosure documents so you better understand the scope and terms of our relationship with you, the conflicts of interest that are associated with a recommendation, the fees and expenses you will pay, and the risks involved if you proceed with the recommended transaction. Don’t hesitate to ask your financial representative to explain any of the written disclosures to you. If you require further information, please contact us at 818-781-7721.

Our Care Obligation

Our care obligation starts with performing reasonable diligence to understand the potential risks, rewards, and costs associated with a security or strategy. We will then carefully gather information to help us understand your financial needs, goals, resources, risk tolerance, and preferences. Finally, we will use our financial expertise to consider the information gathered from you and weigh it against the universe of options available to us that present a reasonable solution. We will only make a recommendation if it is consistent with your financial goals, risk tolerance, investment time horizon, and expectations and we believe it is in your best interest.

Acting in your best interest means that the recommendations we provide are the logical result of the process described above. Our recommendation may be a commission-based product, a fee-based account, or a combination of the two. We will take as much time as needed to make sure you understand the recommendations we make.

You should understand the process we follow when making recommendations. We rely on the information you provide so make sure that it is complete and accurate. You should discuss this and all disclosures in this document with your financial representative. If you require further information, please contact us at 818-781-7721.

Our Conflicts of Interest Obligation

Conflicts of interest are inherent in the financial services industry. Conflicts of interest – real or apparent – are instances where a person or firm has an incentive to serve one interest at the expense of another.

JKR avoids certain conflicts and seeks to manage unavoidable conflicts through disclosure and with policies and procedures that are designed to protect customer interests. We are committed to conducting business ethically and transparently.

You need to be aware of potential conflicts of interest in the recommendations you receive. Most conflicts relate to how compensation is received by JKR and its financial representatives. Be sure to read our Brokerage Compensation and Conflicts of Interest Disclosure document and discuss this topic with your financial representative. If you require further information, please contact us at 818-781-7721.

Our Compliance Program Obligation

We have a compliance program in place that we believe is reasonably designed to place your interests ahead of ours when we provide a recommendation to buy, sell, hold, exchange, or transfer an investment. This program includes written policies and procedures covering topics such as risk management and internal controls, ethics, conflicts of interest, supervision, continuing education and training, recordkeeping, among many others.

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