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Managing Conflicts of Interest
NCM Financial Services LLC ("NCM" or "the Company", "we", "us", or "our") is committed to helping identify and manage conflicts of interest that may arise when we deal with our clients, and to avoid instances and examples of when a conflict may arise.
The Company ensures all reasonable measures have been taken to protect our clients and to prevent conflicts of interest which may lead to a material risk of damage to our clients.
Circumstances which can give rise to a conflict when we provide services to our clients:
- When the Company executes a transaction on behalf of a client, it is entering into a trade as a Principal, and will be the counterparty to the transaction.
- When a client is introduced to us by a referral, the Company may receive commission on these trades.
A conflict of interest could arise between the Company and its clients, or between the interest of a client and our other clients. Conflicts of interest may arise in the course of the Company providing a service to its clients when the Firm or the relevant person:
- Is likely to make a financial gain/avoid financial loss at the expense of the client.
- Has an interest in the outcome of a service provided/or transaction carried out on behalf of the client which is different from the client’s interest in that outcome.
- Has a financial or other incentive to favor the interest of another client or group of clients over the interest of a client.
- Receives a commission or fees from a person other than the client, in relation to a service provided to the client.
- Carries on the same business as the client.
Controls
The Company maintains records of the kinds of activity carried out by the firm, in which a material conflict could potentially arise, or has arisen. The Company also implements procedures and controls to manage actual or potential conflicts.
This includes procedures to maintain appropriate independence between NCM staff to protect the transfer of information, segregation of duties and responsibilities and physical separation of staff.
The Company maintains a record of gifts received by staff members from other parties, to ensure gifts are reasonable and not excessive.
Disclosures
Where our arrangements to manage conflicts are not sufficient to be reasonably confident that risks of damage to a client’s interest will be prevented, we aim to disclose the general nature and/or sources of conflicts before carrying on business for the client.
The Company may even decline to act on behalf of a potential client in cases where a conflict is identified.
Contact Us:
Please feel free to contact us at compliance@ncmfinancials.com if you are aware of circumstances which have led to/or may lead to a conflict of interest, or anticipate that a potential conflict may arise, or if you have any questions or would like more information.