Acting outside of IPS mandate (for tactical allocation) -- Disclose when?

CFA Level III
#1

I thought before you made any tactical moves, but AMC page 273 5.)(a) indicates “best practice is for managers to disclose such events to clients when they occur, _ or , at the very least, in the course of normal client reporting _.”

But then #7 in the vignette on page 287 basically says that since the manager made changes and didn’t disclose until the next annual newsletter (due in 3 months) that it is a violation. I know its an “annual newsletter” and not normal reporting, but the line is still gray to me.

In general, if you deviate from the IPS, should you not get approval BEFORE hand. Does it hinge on having a pre-agreed upon tactical allocation percentage or something where you don’t need to get pre-approval but do need to notify in normal reporting?

#2

Look at Page 264 #2. “Under no circumstances should a maanger take investment aciton that is inconsistent with the client’s IPS.”

I think page 274 5a is referring to the discosure of market movements, not the actual reallocation.

#3

I think in 287 it is different because it is a fund he is managing and “broadened the fund’s strategy”. It is not a portfolio for a specific client. He did not violate the IPS of the fund by making this change.

#4

i mean he works at “an investment advisory firm managing portfolios for individuals”.

of course it’s for specific clients.