"morality" exercise: Diligence and Reasonable Basis

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Questions 1:

Alexandra Smirnov, CFA, is a pension consultant to the Springwell Pension Fund. After reviewing Springwell’s three-year performance presentation showing the fund’s underperformance relative to its investment objectives and agreed benchmarks, Smirnov recommends that the fund hire new asset managers. Smirnov proposes that the fund hire Newday Managers on the basis of recent meetings she has had with the firm. Lengthy discussions at these meetings included Newday’s investment strategy,its suitability to manage pension funds, its ability to adhere to its stated strategy, the firm’s historical investment performance, and its adoption of the CFA Institute Code and Standards. Smirnov turned down Newday’s offer of an introduction fee when recommending its services, but did not inform Springwell trustees of this offer. Which of the following CFA Institute Standards does Smirnov most likely violate?

A 、Referral Fees

B、 Loyalty, Prudence, and Care

C 、Diligence and Reasonable Basis

Questions 2:

Kam Bergeron, CFA, is an equity portfolio manager who often takes time off in the afternoon to play golf with important clients. Today, Bergeron is on the golf course when his game is interrupted by a phone call from his office. The call is from Bergeron’s assistant, who notifies him of a steep and accelerating market

decline. Bergeron, eager to get back to his golf game, tells his assistant to raise cash by selling 15% of all clients’ holdings. Bergeron instructs his assistant to first sell the most liquid stocks in each client’s portfolio and then do the same for his personal account. Bergeron is least likely to be in violation of which of the CFA Institute Standards of Professional Conduct?

A 、Suitability

B、 Priority of transactions

C、 Diligence and reasonable basis

View answer resolution

【Answer to question 1】C

【analysis】

C is correct because Smirnov violated Standard V(A)–Diligence and Reasonable basis because she recommended an external advisor without first understanding the adviser’s compliance and internal control procedures. She was correct in seeking to understand the proposed fund manager’s code of ethics, quality of performance returns, and ability to adhere to its stated investment strategy, but to complete her work she also needed to perform due diligence about the firm’s compliance and internal control procedures.

A is incorrect because Smirnov refused the referral fee [Standard VI(C)–Referral Fees], so she did not need to inform her client of this matter. There is also no indication that she did not act with reasonable care and prudent judgment when recommending a change in asset managers to meet the objectives of the client.

B is incorrect because there is no indication that she did not act with reasonable care and prudent judgment when recommending a change in asset managers to meet the objectives of the client. Nor is it evident that she had any conflicts of interest when recommending a particular manager, especially because she refused the referral fee.

【Answer to question 2】B

【analysis】

B is correct, as the manager gives instructions to sell his personal holdings after those of his clients so there is no indication that a violation of Standard VI(B)–Priority of Transactions occurred.

A is incorrect, as it is not clear selling a fixed percentage of all liquid stocks would be an investment action consistent with the stated objectives and constraints of each client’s portfolio.

C is incorrect as the decision by the manager to conduct an across the board sale of liquid stocks does not appear to have a reasonable and adequate basis nor to be supported by appropriate research and investigation. This action appears to be motivated by the manager's interest in getting back to his golf game rather than any investment rationale.

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