NO.PZ2024102501000003
问题如下:
Mason Dixon, CFA, a portfolio manager with Langhorne Advisors (“Lang horne”), has just completed the RFP for the Academe Foundation’s (“the Founda tion”) USD20 million fixed-income mandate. In the performance section of the RFP, Dixon indicated that Langhorne is a member firm of CFA Institute and has prepared and presented this performance report in compliance with the Glob al Investment Performance Standards (the GIPS® standards). The performance report presented Langhorne’s fixed-income composite returns on the actual net-of-fees basis and benchmark returns, net of Langhorne’s highest scheduled fee (1.00% on the first USD5 million; 0.60% thereafter). The report also indicated that as of the most recent quarter, the composite comprised 10 portfolios totaling USD600 million of assets under management.
Upon returning the completed RFP, Dixon thanked the Foundation’s CIO, who is also a charterholder, for considering Langhorne. Dixon also indicated that regardless of the outcome of the manager search, he would like to have the CIO and the Foundation’s president join him on Langhorne’s corporate jet to spend a day at an exclusive California golf club where the firm maintains a corporate membership.
Identify the ethical concerns posed by Dixon’s actions and conduct.
选项:
解释:
Dixon’s actions and conduct pose multiple ethical concerns.
Dixon’s claim of compliance statement and cover letter, along with Langhorne’s performance report, violate both the CFA Institute Code of Ethics and Standards of Professional Conduct (Code and Standards) and the GIPS standards. Regard ing the Code and Standards, Dixon’s statement improperly asserts that CFA Institute has designated Langhorne as a “member firm.” Membership is held by practitioners as individuals, with no related rights extended to the firms at which they work. With this assertion, Dixon has misrepresented Langhorne’s claim of compliance, Standard I(C): Misrepresentation; engaged in conduct that compro mised the reputation or integrity of CFA Institute, Standard VII(A): Conduct as Participants in CFA Institute Programs; and misrepresented or exaggerated the meaning or implications of membership in CFA Institute, Standard VII(B): Refer ence to CFA Institute, the CFA Designation, and the CFA Program.
Regarding the GIPS standards and the performance report, presenting composite returns on a net-of-fees basis is acceptable under the GIPS standards. However, adjusting benchmark returns with a hypothetical fee for comparative purposes (i.e., composite gross-of-fees returns should be compared to unadjusted bench mark returns) is not appropriate. This adjustment of Langhorne’s performance report is invalid under the GIPS standards under Section 4.a.1: Disclosure— Requirements. The 1.00% hypothetical fee deducted from benchmark returns is surely greater than the average fee deducted in arriving at composite net-of-fees returns. An average portfolio size of USD60 million implies a composite fee percentage of roughly 0.63%, or: {(0.0100 × USD5 million) + [0.0060 × (USD60 million – USD5 million)]}/USD60 million = 0.0063 or 0.63%. So, on a relative basis, deducting a larger cost against the benchmark will show Langhorne with a phantom outperformance.
In terms of the Code and Standards, at a minimum, Dixon has presented an inac curate performance comparison—Standard III(D): Performance Presentation— and might have engaged in misrepresentation to the point of misconduct— Standard I(D): Misconduct—casting a more favorable light on the Langhorne composite net-of-fees returns could be deceitful (Section 0.A.7 under Fundamen tals of Compliance—Requirements of the GIPS standards).
Dixon’s cover letter invitation for an all-expenses-paid outing to an exclusive golf destination can be construed as an attempt to influence the independence and objectivity of the Foundation’s CIO and president—Standard I(B): Independence and Objectivity. While Dixon’s invitation was extended “regardless of the out come of the manager search,” the offer could be interpreted as a quid pro quo, with future attractive personal benefits available to the Foundation’s executives if a continuing relationship was established by their hiring of Langhorne as a manager.
如题