Washington is a senior portfolio manager for Valley Forge As…

Written by Anonymous on August 23, 2026 in Uncategorized with no comments.

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Wаshingtоn is а seniоr pоrtfolio mаnager for Valley Forge Asset Management, a US registered investment adviser and broker/dealer. Valley Forge provides advisory services on a discretionary basis to approximately 2,000 separately managed retail and institutional accounts, focusing its investments on large-capitalization stocks and fixed-income securities. Valley Forge offers its advisory clients three choices for brokerage services, all of which are outlined in its investment advisory contract with clients: Affiliated Brokerage, Directed Brokerage, or Discretionary Brokerage.   Under an Affiliated Brokerage, clients can direct their brokerage to Valley Forge’s own “full-service brokerage.” Valley Forge discloses in the client agreement that this arrangement could be viewed as a conflict of interest, the firm would benefit monetarily, similar services by other brokers may be offered at lower prices, and clients should “carefully consider the services offered relative to the brokerage commission being paid.” But Washington informs clients that they can negotiate a commission rate, and that the firm is willing to provide a discount of at least 70% off Valley Forge’s “full commission rate.” Around 1,200 clients choose Affiliated Brokerage, and 92% of these clients received the 70% discount.   The Directed Brokerage allows clients to designate a third-party broker/dealer to handle all aspects of the brokerage relationship. Under this option, the client negotiates the fees and/or commissions directly with the third-party broker/dealer. Of the nearly 840 clients who choose this option, approximately 690 clients choose Broker B, a broker referred by Washington. Under the Discretionary Brokerage, clients choose where their assets will be custodied and designate a “preferred broker,” but Valley Forge has discretion to select the broker/dealer for each trade on a “best price and execution basis.” Only about 24 clients choose this option.   Washington does not disclose what services Valley Forge provides to its Affiliated Brokerage clients, and Valley Forge does not provide any services to its Affiliated Brokerage clients that are not also provided to clients who choose the other brokerage options. The brokerage costs under the Affiliated Brokerage are 4.5 times higher than those under the other two options, even with the 70% discount on Valley Forge’s supposed retail brokerage rate. Nearly every trade is more expensive with the Affiliated Brokerage option because the minimum commission per trade is more than double the maximum commission charged for each trade under the other options. Washington’s actions are

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