Guerriere has adopted the CFA Institute Asset Manager Code of Professional Conduct and notified the CFA Institute. Guerriere appointed a current employee at the firm, Alex Dziadosz, CFA, as chief compliance officer. Dziadosz also retains his duties to underwrite potential funds and coinvestments.
Which of the following best describes Guerriere’s appointment of a compliance
officer?
A. The Asset Management Code of Conduct does not require the appointment of a compliance officer.
B. The Asset Management Code of Conduct allows for a chief compliance officer who is an employee of the firm.
C. The appointment of Dziadosz as the chief compliance officer violates the Asset Management Code of Conduct because of his other duties at the firm.
Item D of the Asset Manager Code of Professional Conduct involves Risk Management, Compliance, and Support. Managers must appoint a compliance officer responsible for administering the policies and procedures and for investigating complaints regarding the conduct of the manager or its personnel. Managers may designate an existing employee to also serve as the compliance officer.
I thought the compliance officer must be independent of the investment personnel? Or is co-investing not included here?