Asset Mgr code and Valuation

Valuation methods: In the Performance and Valuation, CFAI says to get 3rd party valuations because of the conflict in inflated valuations from a fee perspective. Then in Disclosures, they say clients need to know if assets in portfolio are valued using 3rd party valuations or Internal valuation models. My question is this: can internal valuation models be used and still be in compliance with the code?

Use fair market prices to value client holdings and apply, in good faith, methods to determine the fair value of any securities for which “no readily available, independent, third-party market quotation is available” => I guess it mean if no readily available third party market quote, can use internal valuation method to determine fair market value.

I have not read the asset manager code, do they usually test this?

I am leaving the whole of Ethics to almighty! … Still not tocuhed it and the situation should stay the same till I hit 1st day of June.

BiPolarBoyBoston Wrote: ------------------------------------------------------- > I have not read the asset manager code, do they > usually test this? Well, it is the one topic under the Ethics umbrella that isn’t touched in LI or LII…what do you think?

phuck me, i know what im doing this weekend.

Its almost exactly like the Code with just a few twists like: 6 years worth of records, its for the firm only, its a minimum set of standards for the firm, you need to have a Compliance Officer report to the CEO or BoD, need to give performance reports within 30 days after the quarter, etc. Overall its not a difficult read. What could be nice for us to do is compile the differences between the AMC and the Code & Standards.