Financial Anti Steering Agreement

FINANCIAL ANTI STEERING AGREEMENT

Parties and Effective Date

This Financial Anti Steering Agreement (the Agreement) is entered into between Provider Name: and Client Name: .

Effective Date:

Recitals

WHEREAS, Provider maintains and offers financial products and services to clients and may pay or receive compensation in connection with such products and services; and

WHEREAS, Client requires that recommendations, sales activity, placement, or referrals involving Client's accounts be made on the basis of the Client's best interest and not on the basis of payments, incentives, or other arrangements that would improperly influence product placement ("steering");

NOW, THEREFORE, in consideration of the mutual covenants set forth herein, the parties agree as follows.

Definitions

"Steering" means any practice or communication by Provider or its Representatives that directs, influences, or attempts to influence Client to select a particular financial product, service provider, platform, or service channel for reasons other than the Client's stated investment objectives, needs, and best interest.

"Compensation" includes, but is not limited to, fees, commissions, finder fees, revenue sharing, soft dollars, marketing support, override payments, and any other monetary or non-monetary benefits.

Anti-Steering Covenants

1. Provider covenants that it will not engage in Steering with respect to Client's accounts, shall not condition recommendations on the receipt of Compensation, and shall not favor products, services, or distribution channels on the basis of compensation arrangements where such preference conflicts with Client's best interest.

2. Provider shall ensure that all Representatives who provide advice, recommendations, or placement services to Client receive training and written directives necessary to comply with the anti-steering obligations set forth in this Agreement.

Disclosure of Compensation

Provider shall disclose in writing to Client, no less frequently than annually, a complete description of compensation arrangements that could reasonably be expected to influence placement or recommendation decisions affecting Client. Provider shall also promptly disclose material changes to such arrangements.

Prohibited Conduct

Provider shall not: (a) alter, delay, or withhold information to influence Client choice of product or provider; (b) mischaracterize the relative costs, benefits, or risks of available alternatives; (c) require use of specific platforms, custodians, or intermediaries as a condition of receiving access to any product or service unless such requirement is disclosed and consistent with Client's best interest.

Permitted Exceptions

The restrictions herein do not apply to actions that are: (a) required by law or regulatory obligation; (b) necessary to preserve the integrity of Client accounts in exigent circumstances; or (c) expressly documented in writing as agreed exceptions by Client. All exceptions must be documented contemporaneously with a written justification.

Recordkeeping, Reporting and Audit Rights

Provider shall maintain records demonstrating compliance with this Agreement for a period of years following the final transaction or interaction. Client or Client's authorized auditor shall have the right, upon reasonable notice, to inspect and copy relevant records during normal business hours.

Representations and Warranties

Each party represents and warrants that it has the authority to enter into this Agreement and that the execution and performance of this Agreement will not violate any material agreement or law to which it is subject.

Indemnification and Limitations

Provider agrees to indemnify, defend and hold harmless Client from and against any losses, claims, damages, fines, penalties and expenses (including reasonable attorneys' fees) arising out of Provider's breach of this Agreement or violations of applicable law attributable to Provider's steering. Except for indemnification obligations, neither party shall be liable for consequential, incidental, exemplary or punitive damages except in cases of willful misconduct or gross negligence.

Term and Termination

This Agreement shall commence on the Effective Date and shall continue for a term of years unless earlier terminated in accordance with this Agreement. Either party may terminate this Agreement for convenience upon days' prior written notice. Termination does not relieve Provider of obligations with respect to actions or omissions occurring prior to termination.

Compliance; Remedies for Breach

Upon a material breach of this Agreement by Provider, Client may, in addition to any other remedies available at law or equity, require corrective actions, seek monetary damages, or terminate the Agreement. Provider shall cooperate with any investigation and shall implement remedial measures reasonably requested by Client.

Notices

Governing Law and Dispute Resolution

This Agreement shall be governed by the laws of the State of without regard to conflict of laws principles. Any dispute arising under this Agreement shall be resolved in the courts located in , State of .

Miscellaneous

This Agreement constitutes the entire agreement between the parties with respect to the subject matter herein and supersedes all prior agreements and understandings. Any amendment must be in writing and signed by authorized representatives of both parties. If any provision is held invalid, the remainder shall remain in full force.

Compliance Certifications

The undersigned representatives certify that they are authorized to bind their respective parties, that the information provided in this Agreement is true and correct, and that they will perform their obligations in good faith and in accordance with applicable laws and regulations.

Sign Now