In Ethics, under research reports, says all supporting documentation should be kept for 7 years. Under Compliance & Support for Asset Managers Compliance, says all records should be kept for 6 years. Are these 2 distinct from one another?
6 under Ethics is recommended 7 under Asset Manager Code is required
did you get that backwards bigwilly? Code & Standards = 7 years Asset Manager Code = 6 years When in doubt, follow the stricter of the two laws – Code & Standards. I don’t know why they introduce these conflicting, confusing points that add no value. I mean seriously, in case we don’t already have enough to remember.
Remember that Ethics is individual-focused and Asset Manager Code is firm-focused so they aren’t really contradicting each other. This is the kind of stuff CFAI likes to test you on.
No, I didnt check any notes, but I think what I put is correct…
asd is correct… 7 years for research report supporting documents and 6 years for Asset Manager Code.
U sure? I could have sworn it was teh otehr way around…
on this one, i am 100% sure. i hope this is on the test lol.
this is the single difference between ethics and the asset manager code there is other one: cash gifts from clients are not allowed under the asset manager code (and this is not mentioned in ethics anywhere)
interesting… I would think that Cash Gifts would be unacceptable on all levels.
I always accept Cash 
hala_madrid Wrote: ------------------------------------------------------- > this is the single difference between ethics and > the asset manager code > > there is other one: cash gifts from clients are > not allowed under the asset manager code (and this > is not mentioned in ethics anywhere) it is mentioned in ethics to the extent that an additional compensation arrangement between a client and a manager that includes a cash payment must be disclosed to management. this allows management to monitor the account and prevent behavior that disadvantages other clients who are not providing the additional compensation. in the AMC, you can’t receive cash, period. those are the only two differences i remember…
Good to know… Thanks!
asdffdsa Wrote: ------------------------------------------------------- > hala_madrid Wrote: > -------------------------------------------------- > ----- > > this is the single difference between ethics > and > > the asset manager code > > > > there is other one: cash gifts from clients are > > not allowed under the asset manager code (and > this > > is not mentioned in ethics anywhere) > > it is mentioned in ethics to the extent that an > additional compensation arrangement between a > client and a manager that includes a cash payment > must be disclosed to management. this allows > management to monitor the account and prevent > behavior that disadvantages other clients who are > not providing the additional compensation. in the > AMC, you can’t receive cash, period. > > those are the only two differences i remember… That is my point: under ethics, if disclosed and accepted, you can take the cash gift. Under the asset manager code, no cash gifts
i believe token gifts used to be less than $ 100 but this year they dont indicate an amount . Cash is never acceptable . What if somebody sends you flowers what are you supposed to do …?? Send them back if your boss disapproves for whatever reason ?
i think flowers are fine
token gifts are fine Differences I didnt know about cash but 1) You have to designated compliance officer (might be external or internal) 2) Compliance office has to report to CEO 3) COB plan is required 4) And the whole bunch of disclosures which i dont currently remember
Compliance officer cannot be from operations or investment department.
where did you guys get this info about compliance officer not being part of operations or investment department? That’s strange considering that most Investment Advisors’ compliance manager is the branch manager within the same office as them. They report directly to them and also have them sign off as a compliance officer.
I think it is under IV.C, Responsibilities of supervisors