{ "docId": "019dd923-5e88-73ef-bd5a-28c72cc9d740", "docSlug": "1b9c53be021f8188", "documentTitle": "asset and wealth management mn", "authorId": "GoldmanSachs", "authorName": "Goldman Sachs", "documentKindSlug": "consulting-deck", "documentKindLabel": "Consulting deck", "sourceTypeSlug": "equity_research", "sourceTypeLabel": "Equity research", "presentationDate": null, "orientation": "portrait", "aspectRatio": 0.773, "pageNumber": 136, "pageCount": 183, "prevPage": 135, "nextPage": 137, "slideType": "appendix_disclosure", "function": "other", "density": "overcrowded", "nDataPoints": 0, "notes": "This is a regulatory disclosure page from a Form ADV document.", "elementsJson": [ "paragraph" ], "metadataConfidence": 1, "imagePath": null, "slideHref": "/slides/019dd923-5e88-73ef-bd5a-28c72cc9d740/136", "deckHref": "/decks/019dd923-5e88-73ef-bd5a-28c72cc9d740", "deckJsonHref": "/decks/019dd923-5e88-73ef-bd5a-28c72cc9d740.json", "deckAnchorHref": "/decks/019dd923-5e88-73ef-bd5a-28c72cc9d740#slide-136", "components": [ { "bbox": { "h": 0.115, "w": 0.744, "x": 0.128, "y": 0.435 }, "kind": "paragraph", "text": "GSAM only accepts an Advisory Account's reasonable directed brokerage instructions (including for commission recapture arrangements) pursuant to appropriate written direction, including representations that may be requested from Advisory Accounts. In considering whether a request to direct brokerage for an Advisory Account can be accommodated, GSAM will consider any operational or other concerns regarding the designated broker-dealer. GSAM may, in its sole discretion, seek to accommodate an Advisory Account's direction by arranging \"step outs\" to the client's designated broker-dealers from an aggregate order on behalf of the directing Advisory Account and other Advisory Accounts.", "attrs": null, "subkind": "paragraph", "toolName": null, "toolSlug": null, "confidence": null, "componentId": "0bf9f4a1-cbca-4a68-bd94-b93990d7a76a", "frameworkName": null, "frameworkSlug": null }, { "bbox": { "h": 0.085, "w": 0.744, "x": 0.128, "y": 0.81 }, "kind": "paragraph", "text": "GSAM may effect transactions through an Advisory Account's directed broker-dealer at the commission rates agreed to by the Advisory Account with the directed broker-dealer or at the directed broker-dealer's standard rate if no specific rate has been negotiated. Such rates may be higher than the rate GSAM may have obtained if GSAM had full brokerage discretion. Advisory Accounts that direct brokerage may have execution of their orders delayed, since, in an effort to achieve orderly execution of transactions, execution of orders for Advisory Accounts that have directed GSAM to use particular broker-", "attrs": null, "subkind": "paragraph", "toolName": null, "toolSlug": null, "confidence": null, "componentId": "25dcfd34-e161-47f7-801e-aca68ad55a31", "frameworkName": null, "frameworkSlug": null }, { "bbox": { "h": 0.085, "w": 0.744, "x": 0.128, "y": 0.555 }, "kind": "paragraph", "text": "GSAM may agree to seek to accommodate direction requests only with respect to a limited percentage (or \"target\") of certain Advisory Accounts' overall trades. There can be no guarantee that any target will be achieved, and some directing Advisory Accounts may have a greater proportion of their targets achieved than others. GSAM reserves the right to decline directed brokerage instructions where it believes such trading direction could interfere with its fiduciary duties, or for other reasons, determined in GSAM's sole discretion.", "attrs": null, "subkind": "paragraph", "toolName": null, "toolSlug": null, "confidence": null, "componentId": "48d20551-e34e-4ba4-bae1-c43ce6d7f0d4", "frameworkName": null, "frameworkSlug": null }, { "bbox": { "h": 0.115, "w": 0.744, "x": 0.128, "y": 0.69 }, "kind": "paragraph", "text": "Where an Advisory Account directs the use of a particular broker-dealer or restricts the use of certain broker-dealers, it is possible that GSAM may be unable to achieve most favorable execution of Advisory Account transactions, and the Advisory Account may be disadvantaged as a result of a less favorable execution price and/or higher commissions. GSAM does not typically evaluate or monitor the nature and/or quality of the services that directing Advisory Accounts receive through their directed arrangements. In addition, less favorable execution prices and/or higher commissions could result from the Advisory Account's inability to participate in aggregate orders or other reasons.", "attrs": null, "subkind": "paragraph", "toolName": null, "toolSlug": null, "confidence": null, "componentId": "590f632e-68bd-47e6-8466-88e728ac049e", "frameworkName": null, "frameworkSlug": null }, { "bbox": { "h": 0.115, "w": 0.744, "x": 0.128, "y": 0.315 }, "kind": "paragraph", "text": "Advisory Accounts may, subject to agreement with GSAM and such limitations as may be imposed by GSAM, direct brokerage as part of their participation in a commission recapture program, or for other reasons. These arrangements may involve a client direction to GSAM to place transactions on behalf of an Advisory Account with a particular broker-dealer, including an affiliate of GSAM, or to use a specific execution venue or exchange. Advisory Account directions may be part of an arrangement between an Advisory Account and the relevant broker-dealer or as a result of Advisory Account preferences.", "attrs": null, "subkind": "paragraph", "toolName": null, "toolSlug": null, "confidence": null, "componentId": "5aaf9c62-2470-46c9-83ec-3f4139339e56", "frameworkName": null, "frameworkSlug": null }, { "bbox": { "h": 0.115, "w": 0.744, "x": 0.128, "y": 0.175 }, "kind": "paragraph", "text": "General\nGSAM generally has the discretionary authority to determine and direct execution of portfolio transactions for discretionary investments made by GSAM on an Advisory Account's behalf without prior consultation with the Advisory Account on a transaction-by-transaction basis. Advisory Accounts may limit GSAM's discretionary authority in terms of the selection of broker-dealers or other terms of brokerage arrangements. From time to time, Advisory Accounts may also retain GSAM on a non-discretionary basis, requiring that portfolio transactions, and their execution, be discussed in advance and executed at the Advisory Account's direction.", "attrs": null, "subkind": "paragraph", "toolName": null, "toolSlug": null, "confidence": null, "componentId": "868992b1-f6df-4beb-a1aa-13bd7be9d358", "frameworkName": null, "frameworkSlug": null }, { "bbox": { "h": 0.015, "w": 0.185, "x": 0.128, "y": 0.118 }, "kind": "title", "text": "DIRECTED BROKERAGE", "attrs": null, "subkind": "headline", "toolName": null, "toolSlug": null, "confidence": null, "componentId": "a131535a-43db-4009-b14f-17ec63e06d5a", "frameworkName": null, "frameworkSlug": null }, { "bbox": { "h": 0.015, "w": 0.45, "x": 0.128, "y": 0.66 }, "kind": "title", "text": "Certain Effects of Directed Brokerage on Directing Advisory Accounts", "attrs": null, "subkind": "subtitle", "toolName": null, "toolSlug": null, "confidence": null, "componentId": "355951c3-ee3a-47a3-8f57-92e43b1caca3", "frameworkName": null, "frameworkSlug": null } ], "metrics": [], "tools": [], "frameworks": [], "arcBeats": [ { "to": 150, "from": 101, "beatId": "2ffbac36-9b13-45f3-ad44-b7c15a73d480", "arcName": "The Consultant's Gambit", "arcSlug": "consultants-gambit", "beatName": "Impact & Next Steps", "beatSlug": "consultants-gambit-impact-next-steps", "evidence": "The document concludes with information about the firm's code of ethics, participation or interest in client transactions, and other regulatory disclosures.", "position": 4, "confidence": 0.8, "parentBeatName": "Resolution", "parentBeatSlug": "resolution" } ], "loops": [], "imagePathAlt": null, "thumbSrc": null, "thumbSrcAlt": null, "locked": true }