Ethics question. Asset management code. Confused

Hi All this is from the question bank on cfa website.

Bud Walter is the chief investment officer of Wryte Capital Management (WCM). He is meeting with T.M. McGourn, a prospective client, to discuss Wryte’s investment performance as presented in Exhibit 1 and subsequent disclosure notes:

Exhibit 1

Wryte Capital Management US Large-Cap Equity Composite

WCM has prepared this report in compliance with the Global Investment Performance Standards (GIPS). The US Large-Cap Equity Composite has been independently verified by a qualified third party to be GIPS compliant. The verification report was issued only for the composite and not for WCM. It states that during 2009, 2010, and 2011, WCM complied with all composite construction requirements for the composite and that WCM policies are designed to calculate and present performance in compliance with GIPS standards.

Notes:

  1. The firm is defined as an independent investment manager that invests exclusively in US large-cap, US mid-cap, and US small-cap equity securities for US resident clients. WCM’s policy for valuing portfolios and calculating performance is available upon request. WCM’s calculation methodology is to use time-weighted rates of return. Subperiod rates of return are geometrically linked. Cash equivalent instruments are included in rate-of-return calculations. Returns are calculated quarterly or when large external cash flows (as defined by WCM) take place.
  2. The US Large-Cap Equity Composite includes all actual fee-paying portfolios. Each portfolio contains positions in large-cap stocks, which are selected by WCM after an extensive independent analysis. Non-discretionary portfolios are not included in any composite. WCM does not include in any composite its large-cap model portfolio, which is used during the investment selection process.
  3. The composite benchmark is the S&P 500 Index, which represents the size-weighted returns of the 500 largest (as measured by market capitalization) US-based publicly traded companies.
  4. Gross-of-fees returns are presented before investment management fees but after trading expenses, which include custodial fees. All clients pay an investment management flat fee of 75 basis points on the month-end account value plus a 10-basis-point performance fee whenever the composite return exceeds the benchmark return by 100 basis points.
  5. Internal dispersion is the equal-weighted standard deviation of the annual gross returns of the five portfolios included in WCM’s US Large-Cap Equity Composite.

s WCM most likely compliant with GIPS standards required for composite construction as disclosed in Note 2?

  1. Yes.
  2. No, because of how the large-cap model portfolio is treated.
  3. No, because of how non-discretionary portfolios are treated.

Answer is A

I thought it was B. But the explanation is B is incorrect because WCM does comply with GIPS standards with respect to non-discretionary portfolios since their performance results are not included in any composite.

How do we know that the large cap model is non-discretionary. Where does it say this?

It’s . . . um . . . a model portfolio.

1 Like