Customer allocation discussions are prohibited because participants must not use GRA to divide customers, clients, borrowers, policyholders, investors, sponsors, public agencies, municipalities, project proponents, or institutional relationships.
GRA’s environment may include financial institutions, insurers, brokers, consultants, technology providers, sponsors, project proponents, and public-sector participants. It would be unsafe for participants to discuss who should serve which customer, which firm should pursue which client, which insurer should handle which account, which bank should approach which borrower, or which adviser should control which project.
Even casual conversation can create risk if participants appear to divide opportunities, avoid competing for certain customers, or coordinate outreach strategies.
GRA may support routing within its own official pathways, such as assigning a matter to an appropriate docket, sector platform, Council review, or official workspace. That routing is administrative and governance-based. It is not commercial customer allocation.
Participants should not discuss customer lists, client targets, pipeline opportunities, account strategies, or customer ownership.
The safe principle is: GRA routes records. It does not divide customers.
