关于AMC业绩披露频率

问题如下：

Bornelli Asset Management offers traditional long-only funds as well as a variety of hedge funds for both private and institutional clients. Bornelli is a well-managed firm of more than

100 employees. Its board of directors has voted to adopt the Asset Manager Code of Professional Conduct (the Code).

Bornelli has hired Ava Campanelli as chief compliance officer with responsibility for implementing the Code. Campanelli develops a plan to evaluate the firm’s current policies and procedures for compliance with the Code. Campanelli begins by reviewing three of the firm’s compliance procedures:

Portfolio review Portfolio information provided to clients is reviewed by an independent third-party.

Campanelli then evaluates the firm’s business-continuity plan. Under the current plan, the technology division backs up all of the firm’s computer systems and client records twice daily. The back-ups are stored in a fireproof storage facility offsite. Bornelli outsources certain emergency plans to a disaster recovery firm. The disaster recovery firm is responsible for developing and implementing plans to communicate with employees and mission-critical vendors and suppliers in the event of a facility or communication disruption. The same firm also provides plans for contacting and communicating with clients in event of an extended disruption.

For her next project, Campanelli reviews the disclosures provided to both prospective and current clients. The disclosures regarding management fees state:

Bornelli charges a 2% asset-based management fee. In addition to the management fee, clients may pay an incentive fee at the end of each year. The incentive fee is equal to 20% of the account’s net investment income and net realized and unrealized capital gains for the year.

No incentive fee will be paid unless the Fund has offset all prior net realized capital losses and net investment losses with realized capital gains, unrealized appreciation, and net investment income from all securities held by the Fund.

Campanelli’s evaluation of the management fee disclosures is interrupted by a more urgent matter involving a client. The client has requested monthly performance reporting of his investment in a long-short equity hedge fund. The fund’s administrator argues "Our procedures call for us to provide clients with both gross- and net-of-fees returns within 30 days of the end of the quarter." He adds "Quarterly reporting is the industry standard."

The administrator complains "This client, Rossi, is overly demanding. He telephoned yesterday and requested an itemization of the fees and other costs charged to him for the past three years. He wants to know the specific management fee, the incentive fee, and the amount of commissions paid. The more time we spend answering his requests, the less time we have to research investments." Campanelli promises to look into the matter for the administrator.

The following week, Campanelli meets with Lee Bruno, manager of the firm’s alternative assets fund. Bruno informs Campanelli, "The fund has a three-year lock-up period. We disclosed to all the prospective clients in writing before they invested that this is a long-term investment and that they should not focus on short-term performance results. During the lock-up period, we provide semiannual reporting. After the lock-up, we report quarterly."

Bruno informs Campanelli that whenever possible, the firm uses fair market prices to value client holdings. He adds "Of course, our fund invests in alternative assets—some of which are very difficult to value. They aren’t like public equities with independent, third-party market quotations available, so we use an internal model to value client holdings." He continues, "We disclose the use of internal models for valuation purposes on all our reports."

Following her conversation with Bruno, Campanelli researches a complaint from a new client regarding the valuations of his fund’s holdings. The client complains that another management firm reported much lower valuations on similar instruments. Campanelli researches the methodologies Bornelli uses for valuing fund holdings. She determines the following:

₤ All publicly traded US and foreign equities, including large-, mid-, small-, and micro-cap shares are valued at the last available closing price.

₤ The value of certain securities such as swaps are based on quotes collected from broker-dealers.

₤ When prices are not available from either of the above sources, valuations are based on internal models.

4. Are the performance reporting procedures described by the fund’s administrator consistent with the required disclosure standards of the Asset Manager Code?

选项：

Yes.

No, because the AMC requires firms to report performance to all clients on a monthly basis.

No, because the AMC requires firms to provide performance on a monthly basis when requested by clients.

解释：

A is correct.

The performance reporting procedures described by the administrator are consistent with the Asset Manager Code (AMC) which requires disclosing the "performance of clients’ investments on a regular and timely basis." The AMC recommends that "managers should report to clients at least quarterly, and when possible, such reporting should be provided within 30 days after the end of the quarter." The AMC also states that "at a minimum, Managers should provide clients with gross- and net-of¬fees returns." Because quarterly reporting is the recommended minimum, managers may choose to provide more timely performance to clients.