Disclosure of conflict/Additional Compensation Question

If a fund manager manages portfolio for family without fee, does he need

A) Written consent

B) to disclose only to employer

C) No permission or disclosure required?

I cant find the answer to this in the Code and Standards Handbook so if anyone can clearly answer this, please chime in.

is the fund manager a beneficiary of the family portfolio??

Lets assume he isnt a beneficiary of the portfolio

From what i remember, there are no specific requirement for disclosure if you are managing any portfolio that you are neither charging a fee or have an ownership of. So this is not an additional compensation question, just to eliminate that from the answers.

HOWEVER, the spirit of disclosure of conflicts states that members or candidates must make full disclosure of all matters that could reasonably be expected to impair their independence and objectivity or interfere with respective duties to their clients, prospective clients and employer.

So, if you are actively managing a portfolio, even if you don’t actually benefit from it, in theory you should still disclose it because it is “expected” to impair your independence in the eyes of prospective clients and employer.

Other candidates/ members please correct me if i’m wrong! :slight_smile:

There could be a problem if the family members are potential clients of your employer. I’d disclose it.

Actually this is very interesting, if the manager has no beneficiary to the portfolio, does it matter if it’s a family member?

I mean, the family member does not live under the same roof, could be a uncle, or second cousin.

What difference does it make to manage a portfolio for a second cousin or a friend?

If there is no difference, everyone can be potential client to the employer, no?