Checklists and templates created at prior firm are IP of the firm - Written consent to use them
Roadshows - Participacion is accepted as long as disclosed.
Show past performance - OK to show, but disclose where it took place and the role performed
Lobbying is OK as long as nothing illegal is done.
Conflicts of interest like corp.finance business has to be disclosed in first place (rather than full separation), so that clients can also benefit when appropriate
Changes in key personnel or regulatory sanctions - Disclose! (not necessary for bonuses and termination packages though)
ACA are only related to competition against employer! If preliminary school teacher in free-time, that would not need to be disclosed (unless its 30 hours per week, cause it could harm employer)
Regular account information should be submitted to the client at least quarterly.
Pay everything if possible** :** accommodation, airplane tickets, etc.
Leaving an employer : Don’t take client info (unless accepted by employer), even if the client has left the firm. Preparatory activities (admin, legal paperwork, etc.) are OK.
High commissions : if service is worth it and there is no other alternative, is OK but disclose it
Course of action hierarchy if suspect of performance misrepresentation (when you hire an investment manager): 1) Consult supervisor, 2) See whistleblowing policies, 3) Discontinue the arrangement (extreme)
Restricted securities on a watch list : every employer should get written and prior approval (no specification of dollar amount)
Disaster recovery system is mandatory, but size, nature, and complexity depends on organization. Off-site back-up records are preferable, but on-line accepted as well if out-of-budget.
Storing account information in electronic form is accepted.
Fees disclosures : required to disclose both gross and net. Procedure to calculate contingent fees has to be disclosed regardless of client request.
Material changes in investment strategy : Managers must provide adequate information to clients before any material change. If the Manager makes a material change in investment strategy or style, clients should be given enough time to consider the proposed changes.
Cash gifts are prohibited! Gifts or entertainment that could impair independence must be refused.
Wrong use of CFA designation (like highlighted in a business card) is OK if the material is never distributed
Most meaningful differences between AM Code and COE are in the Risk Management, Compliance and Support section.
Business continuity plan: includes plans for contacting and communicating with clients during a period of extended disruption.
Firm’s mistake : accounts should be made whole with lost interest as well. Nothing is said in respect to the interest earned by accounts that did not receive shares and asked for them, but normal practice is to do nothing to avoid upsetting clients