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

作出投资决策或投资建议前，评估是否适合客户。

评估整个投资组合是否适合客户。

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. （如果投资前对投资目标及限制进行过约定，投资决策或投资建议要严格遵守该约定）

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. （客户提出了交易是unsuitable的，如果客户坚持，要取得客户的书面同意）

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必须每年更新，如果投资有实质性变化，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. （管理资产组的，无需对个人客户负责）Only those who have advisory relationship are responsible for individual clients.