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The Code prohibits the acceptance of gifts other than of a modest value. There is no dollar amount stipulated in the standards although most likely $200 could be considered excessive. The other requirements in the gift policy appear to conform. The IPO allocation looks bad from the start, but the Code says investments must be fairly distributed among the accounts for which they are suitable. IPO’s are not for everyone, and it is certainly plausible that 40 percent of client accounts are too conservative for such securities. An annual review of investment policy statements is sufficient. Regarding soft dollars, the Code and Standards acknowledges that not every client will benefit from the all research. Such mismatches are unavoidable from a practical standpoint, and as long as brokerage is allocated toward research alone, the firm should be covered