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Recommended Procedures for Compliance Make reasonable efforts to achieve public dissemination of information.. Recommended Procedures of Compliance M&C with control of client assets sh

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2017 Study Session # 1, Reading # 1

Copyright © FinQuiz.com All rights reserved

“CODE OF ETHICS AND STANDARDS

OF PROFESSIONAL CONDUCT”

M&C = Members & Candidates

COE = Code of Ethics

DRC = Disciplinary Review Committee

PCS = Professional Conduct Statement

 DRC of CFAI BOG ⇒ responsible for PCP & enforcement of code & standards

Circumstances Which Can Prompt Inquiry

 Self disclosure by member/candidate on PCS which comprehensively questions professional conduct such as involvement in civil litigation, criminal investigation or any complaint (written) against the member/candidate etc

 Written complaints about member/candidate received by professional conduct staff

 Evidence of misconduct by member/candidate received by professional conduct staff through public source

 A report by CFA proctor of a possible violation during examinations

 CFAI designated officer conducts inquiries

 Professional conduct staff (in writing) may request explanation from subject member/candidate & may:

 Interview the subject member/candidate

 Interview the complainant / third party

 Collect relevant documents& records

 Designated officer may decide:

 That disciplinary sanctions are not required

 To issue a cautionary letter

 To discipline the member/candidate

 If disciplinary sanction is proposed, the subject member/candidate may accept the sanction

 If sanction is rejected ⇒ matter may be referred to CFAI panel for hearing

 Sanctions may include

 Condemnation by member’s peers

 Suspension of candidate’s continued participation in CFAI program

Los1.b

 Act with integrity, competence, diligence, respect, and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues’ in the investment profession, and other participants in the global capital markets

 Place the integrity of the investment profession and the interests of clients above their own personal interests

 Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities

 Practice and encourage others to practice in a professional and ethical manner that will reflect credit on themselves and the profession

 Promote the integrity of and uphold the rules governing capital markets

 Maintain and improve their professional competence and strive to maintain and improve the competence of other investment professionals

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2017 Study Session # 1, Reading # 1

Copyright © FinQuiz.com All rights reserved

Standards of Professional Conduct

1 Professionalism 2 Integrity of Capital Markets 3 Duties to Clients 4 Duties to Employers 5 Investment Analysis,

Recommendations& Actions

6 Conflicts of Interest 7 Responsibilities as a CFAI Member or CFAI Candidate

A Knowledge of Law B Independence & Objectivity C Misrepresentation D Misconduct

2 Integrity of Capital Markets

A Material Non-Public Information B Market Manipulation

3 Duties to Clients

A Loyalty, Prudence, and Care

C Suitability

Confidentiality

D Performance Presentation

4 Duties to Employers

Arrangements

C Responsibility of Supervisors

5 Investment Analysis, Recommendations& Actions

A Diligence & Reasonable

Basis

B Communication with Clients & prospective Clients

C Record Retention

6 Conflicts of Interest

A Disclosure of conflicts B Priority of Transactions C Referral Fees

7 Responsibilities as a CFAI Member or CFAI Candidate

A Conduct as Members and Candidates in

the CFA Program

B Reference to CFA Institute, the CFA Designation, and the CFA Program

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

“GUIDANCE FOR STANDARDS I-VII”

1 Professionalism

 M&C must understand & comply with all applicable laws, rules& regulations (including COE & SOPC)

 These rules & regulations pertain to any govt, regulatory organization, licensing agency or professional association governing their professional activities

 Must comply with more strict law in case of conflict

 M&C must not knowingly participate or assist & must dissociate from any violation of laws

Guidance ⇒ Code & Standards VS Local Law

 Members must know laws & regulations related to their professional activity in all countries where they conduct business

 Adhere to more strict rule while deciding b/w local laws & Codes & Standards of CFAI

 Must comply with local laws related to professional activity

 Never violate Codes & Standards even if activity is otherwise legal

Guidance ⇒ Participation in or Association with Violation by Others

 Members must dissociate or separate themselves from any ongoing client or employee activity which is illegal or unethical

 In extreme case they may have to leave the employer

 May, at first, confront the individual involved

 Approach supervisor or compliance department

 Inaction with continued association may be construed as knowing participation

Recommended Procedures for Compliance-Members

 Members must keep themselves updated with applicable laws, rules & regulations

 Compliance laws must be reviewed on an ongoing basis in order to ensure that they address prevailing laws, CFAI standards & regulations

 Members should maintain current reference material for employees in order to keep them date on laws, rules & regulations

up-to- In doubt, members should seek advice of counsel or their compliance department

 Members must document any violation when they disassociate from any prohibited activity

 Members must encourage their employers to end such activity

 Under some circumstances, it may be advisable or otherwise required by the law to report violations

to governmental authorities

 Standards (CFAI) do not require members to report violations to governmental authorities

 CFAI encourages members, clients & public to submit written report against a CFA member or candidate involved in violation of the CFA Code & Standards

Recommended Procedure for Compliance-Firms

 Members should encourage their firms to:

 Develop and/or adopt a code of ethics

 Highlight applicable laws and regulations to employees

 Establish written procedures for reporting suspected violation of laws, regulations or company policies

 Members incharge of supervision, creation and maintenance of investment services should:

 Be aware of and comply with regulations and laws in their country of origin

 They must be aware of and comply with regulations of countries where products/services will

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

1 B Independence & Objectivity

 M&C must use reasonable care & judgment to achieve & maintain independence &

objectivity in professional activities

 Do not accept any gift, or any type of consideration that may compromise their own or another’s independence & objectivity

Guidance

 Investment process must not be influenced by any external sources

 Modest gifts by clients are permitted

 Allocation of shares in oversubscribed IPO to personal accounts is not permitted

 Distinguish b/w gifts from clients & entities seeking influence to the detriment of the client

 Gifts must be disclosed to the member’s employer either prior to acceptance or subsequently

Guidance-Investment Banking Relationships

 Do not get pressurized from sell-side analyst to issue favorable research on current or prospective investment-banking client

 Disclose conflicts and manage these appropriately while working with investment bankers

in “road shows”

 Ensure effective “firewalls” b/w research/investment management & investment banking activities

Guidance-Public Companies

 Do not limit research to discussions with company management

 Use sources like:

 Suppliers

 Customers

 Competitors

 Analyst must not be pressured to issue favorable research by the companies they follow

Guidance-Buy Side Clients

 Responsibility of portfolio managers to respect and foster intellectual honesty of sell side research

 Portfolio managers must not pressurize sell side analysts

 They may have large positions in particular securities Rating downgrade may adversely affect portfolio performance

Guidance-Fund Manager Relationships

 Members responsible for selecting outside managers should not accept gifts, entertainment or travel that might be perceived to impair member’s independence and/or objectivity

Guidance-Credit Rating Agency

 Members employed by credit rating agencies make sure they prevent undue influence by security issuing firms

 Members using credit ratings must be aware of potential conflicts of interest& therefore may consider independent validation of the rating granted

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

Guidance-Issuer Paid Research

 Analyst’s compensation for such researches should be limited

 Preference is flat fee

 No reward must be attached with report’s recommendation

Guidance-Travel

Best practice ⇒ analysts pay their own commercial travel while attending information events or tours sponsored by the firm being analyzed

Recommended Procedures for Compliance

 Protect the integrity of opinions (unbiased opinion of the analyst) & design proper compensation systems

 Create a restricted list (remove the controversial company from research universe)

 Restrict special cost arrangements (limit the use of corporate aircraft to situations in which commercial transportation is not available)

 M&C should pay for commercial transportations & hotel charges

 Limit the acceptance of gratuities and/or gifts to token items only

 Develop formal policies related to employee purchases of equity or equity related IPOs (strict limits on private placements)

 Effective supervisory & review procedures

 Ensure that research analysts are not supervised or controlled by any department that could compromise the independence of analyst

 Appoint a senior officer with oversight responsibilities for compliance with firm’s COE & all regulations concerning its business

1 C Misrepresentation

M&C must not knowingly make any misrepresentations relating to investment analysis, recommendation, actions or other professional activities

Guidance

 Misrepresentation causes mistrust

 Do not give false impressions in oral, written& electronic communication

 Misrepresentation includes

 Guaranteeing investment performance

 Plagiarism

 Plagiarism ⇒ using someone else’s work without giving him credit

 Misrepresentation also includes deliberately omitting information that could affect investment decision

 Models and analysis developed by others at firm are the property of members can use them without attributing to developers

firm- A report written by another analyst employed by the firm cannot be released as another analyst’s work

Recommended Procedure for Compliance

 Firms should provide employees who deal with clients a written list of firm’s available services and its qualifications

 Employee qualification should be accurately presented as well

 To avoid plagiarism, firm must keep record of all sources and cite them

 Generally understandable and factual information need not to be cited

 Members should encourage firms to establish procedures for verifying marketing claims of third parties whose information the firm provides to clients

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

1 D Misconduct

M&C must not involve in dishonesty, fraud, deceit or commit any act that reflects adversely on their professional reputations, integrity or competence

Guidance

 CFAI discourages unethical behavior in all aspects of members’ and candidates’ lives

 Do not abuse CFAI PCP by seeking enforcement of this standard to settle personal, political or other disputes not related to professional ethics

Recommended Procedures for Compliance

 Firms are encouraged to adopt these policies and procedures to:

 Develop and adopt a code of ethics and make clear that unethical behavior will not be tolerated

 Give employees a list of potential violations and sanctions including dismissal

 Check references of potential employees

2 INTEGRITY OF CAPITAL MARKETS

2 A Material Non-Public Information

Guidance

 Material information ⇒ if disclosure would impact price of security

 If reasonable investor would want the information before making an investment decision

 Nonpublic information ⇒ non-available to the marketplace

 Analyst conference call is not public disclosure

 Selective disclosure causes insider trading

 Prohibition against acting on material non public information extends to securities, swaps, and option contracts

Guidance-Mosaic Theory

No prohibition on reaching an investment decision through public and non-material nonpublic information

Recommended Procedures for Compliance

 Make reasonable efforts to achieve public dissemination of information

 Encourage firms to adopt procedures to prevent misuse of material nonpublic information

 Use a “firewall” within the firm with

 Substantial control of relevant interdepartmental communication  through a clearance like compliance/legal department

 Review employee trades maintain watch, rumor, and restricted lists

 Monitor & prohibit proprietary trading-if a firm is in possession of material non-public information

 Prohibiting all proprietary trading may send a signal to the market firm should take the contra side of only unsolicited customers trade

M&C must not act or cause others to act on the information that is material nonpublic (affect the value of investments)

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

2B MARKET MANIPULATIONS

M&C must not engage in practices that mislead market participants (distort prices or artificially inflate trading volume)

Guidance

 Spreading false rumors is prohibited (which can distort market)

 Standard applies to transactions that deceive market

 By distorting the price-setting mechanism of financial investments

 Securing a controlling position to manipulate the price of a related derivative or the asset

3 DUTIES TO CLIENTS

M&C:

 Have a duty of loyalty to clients & must act with reasonable care & exercise prudent judgment

 Must act for the benefits of clients & place clients’ interests above employers’ or their own interests

Guidance

 M&C must exercise same level of prudence, judgment & care as in management & disposition of their own interests in similar circumstances

 M&C should manage pool of assets in accordance with the terms of governing documents (e.g trust documents)

 Determine the identity of “client’” to whom duty of loyalty is owed (May be an individual or plan beneficiaries in case of pension plan or trust)

 M&C must follow any guidelines set by their clients for the management of their assets

 Investment decisions are judged in the context of total portfolio rather than individual investments

 Conflict arises when “soft dollars” are not used for the benefit of clients

 Cost-benefit analysis may show that voting all proxies may not a beneficial strategy for clients

Recommended Procedures of Compliance

 M&C with control of client assets should submit to each client, at least quarterly, a statement showing funds & securities

 In doubt, M&C should disclose the questionable matter in writing to client & obtain client approval

 M&C should address & encourage their firms to address the following regarding duties to client;

 Follow all applicable rules & laws

 Establish the investment objectives of the clients

 Consider all the information when taking actions

 Diversify investments to reduce risk of loss

 Carry out regular reviews

 Deal fairly with all clients with respect to investment actions

 Disclose conflict of interest & compensation arrangements

 Maintain confidentiality & seek best execution

3 A Loyalty, Prudence & Care

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

3B Fair Dealing

M&C must deal fairly & objectively with clients (when providing investment analysis, making recommendations, taking action or engaging in other professional activities)

Guidance

 No discrimination among clients while disseminating recommendations or taking investment decision

 Fairly does not mean equally ⇒ difference in timings of emails & fax received by clients are normal course of business

 Different services levels are okay as far as they do not adversely affect any client

 Disclose different levels of services to all clients and prospects

 Premium services should be available to all those who are willing to pay for them

Guidance-Investment Recommendation

 All clients must be given fair opportunity to act upon every recommendation

 Clients unaware of the change in recommendation  should be advised before the order is accepted

Guidance-Investment Actions

 Clients must be treated fairly in the light of their investment objectives and circumstances

 Both institutional and individual clients must be treated in a fair & impartial manner

 Member/candidates should not take advantage of their position to disadvantage clients (e.g., in IPOs)

Recommended Procedures for Compliance

 Firms are encouraged to establish compliance procedures to treat customers & clients fairly

 Communicate recommendations simultaneously within the firm & to customers

 M&C should consider the following:

 Limit the no of people who are aware that a recommendation is going to be disseminated

 Shorten the time frame b/w decision & dissemination

 Publish guidelines for pre-dissemination behavior

 Simultaneous dissemination (treat all clients fairly)

 Maintain a list of clients & their holdings

 Develop & document trade allocation procedures

 Disclose trade allocation procedures (must be fair & equitable)

 Establish systematic account review (no preferential treatment to any client or customer)

 Disclose level of services (different levels of services are possible for same or different fees)

3 C SUITABILITY

2.M&C are in advisory relationship 1.When M&C are responsible for a portfolio

with a specific mandate, strategy or style, they must take actions according to the objectives & constraints of the portfolio

Make inquiry into client’s investment experience, risk &

return objectives, financial constraints &

reassess & update this information regularly

Determine investment’s suitability with reference to client’s objective &

constraints &

mandate

Judge the investment suitability in the context of client’s total portfolio

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

Guidance

 Develop IPS at beginning of the relationship

 Consider client’s needs, circumstances & risk tolerance

 Consider whether use of leverage is suitable for the client or not

 Make sure to abide by the stated mandate

Recommended Procedures for Compliance

 Develop written IPS of each client & take the following into consideration:

 Client identification

 Investor objectives

 Investor constraints

 Performance measurement benchmark

 Objectives & constraints should be maintained & reviewed periodically to reflect any changes in clients’ circumstances

 Suitability test policies

3 D Performance Presentations

M&C must communicate fair, accurate & complete investment performance information

Guidance

 Members must avoid misstating performance or misleading clients about investment performance

of themselves or their firms

 Members should not misrepresent past performance or reasonably expected performance

 Members should not state or imply the ability to achieve a rate similar to that achieved in the past

 Indicate if presentation has offered limited information

 Brief presentations should be supplemented with information that detailed report is available on request

Recommended Procedures for Compliance

 Apply GIPS standards

 Consider the knowledge of audience to whom performance presentation is addressed

 Performance of composite rather than single account

 Include performance history of terminated accounts

 Disclosures that fully explain the performance results should be reported

 Maintain data & record used to calculate the performance being presented

3 E Preservation of Confidentiality

M&C must keep information about current, former &

prospective clients confidential unless:

 Information concerns illegal activity

 Disclosure is required by law

 Client or prospective client permits disclosure

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

Guidance

 If a client is involved in illegal activitiesmembers may have an obligation

to report to the authorities

 This standard extends to former clients as well

 Standards do not prevent members from cooperating with CFA PCP investigation

Recommended Procedures for Compliance

 Avoid disclosing information received from client except to the authorized colleagues working for the same client

 Follow firm’s procedures for storing electronic data

 Recommend adoption of such procedures if they are not in place

4 Duties to Employers

M&C:

 Must act for the benefit of their employer

 Not deprive employer of the advantage of their skills &abilities, divulge confidential information or otherwise cause harm to their employer

Guidance

 Do not indulge in the activities that may injure the firm deprive it of profit or advantage of employee’s abilities & skills

 Though clients’ interests have  priority than firm’s interests but consider the effects

of actions on the firm’s integrity and sustainability

 A careful balance b/w managing interests of employer & family manage such obligations with work obligations

 Independent practice for compensation is allowed

 Provide employer notification fully describing all aspects of service

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

Guidance-Leaving an Employer

 Continue to act in employer’s best interest until resignation is effective

 Activities that may constitute a violation include:

 Misappropriation of trade secrets

 Misuse of confidential information

 Soliciting employer’s client prior to leaving

 Self-dealing

 Misappropriation of client lists

 Employer records on home computers, PDA, cell phones or any other medium are property of firm

 After leaving the organization, simple knowledge of names and existence of former clients is not confidential

 Member/candidate can use the experience or knowledge gained with former employer at any other organization

Guidance Whistle-blowing

 In exceptional cases, duty to the employer may be violated in order to protect

a client for upholding the integrity of capital markets

 Whistle- blowing cannot be done for personal gains

Guidance-Nature of Employment

If members/candidates are independent contractors, they still have duty to abide

by the terms of the agreement

4 B Additional Compensation Arrangements

M&C must not accept gifts, benefits, compensation, or consideration that competes with or might reasonably be expected to create a conflict of interest with their employer’s interest unless they obtain written consent from all parties involved

Guidance

 Compensation includes both direct & indirect form

 Additional benefits are also included

 Written consent from employer also includes email communication

Recommended Procedures for Compliance

 Immediately report to employer in written format detailing any proposed compensation and services

 Performance incentives should be verified by the offering party

Recommended Procedures for compliance

 Competition policy (employer restrictions on offering similar services outside the firm)

 Termination policy (how termination is disclosed to clients & staff)

 Incident-reporting procedures

 Employee classification (e.g full time, part time)

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

4 C Responsibility of Supervisors

M&C must make efforts to detect & prevent violations of applicable laws, rules & regulations and Code & Standards by any one subject to their supervision or authority

Guidance

 Members must take steps to prevent subordinates from violating laws, rules, regulations or code & standards

 Make reasonable efforts to detect violations

 Members with supervisory responsibility must ensure that policies regarding investment or non-investment behavior are enforced equally

Guidance-Compliance Procedures

 Members with supervisory responsibility must bring an inadequate compliance system to the firm’s attention and recommend corrective action

 While investigating a violation it is appropriate to limit suspected employee’s activities

 Unless adequate procedures are adopted by the firm, a member must decline in writing from accepting supervisory responsibility

Recommended Procedures for Compliance

 M&C should recommend their employers to adopt a COE

 Separate the COE from compliance procedures

 Adequate compliance procedures:

 Clearly written & accessible manual

 Designate a compliance officer to implement compliance procedures

 Implement system of checks & balances

 Describe the hierarchy of supervision

 Outline scope of procedures & permissible conduct

 Once a compliance program is in place, a supervisor should:

 Disseminate program contents to appropriate personnel & educate them regarding compliance procedures

 Professional conduct evaluation as part of employee’s performance review

 Review employee’s actions & identify violation

 Once a violation is discovered, supervisor should respond promptly, conduct thorough investigation & increase supervision

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

5 Investment Analysis, Recommendations and Actions

1.M&C must exercise diligence, independence & thoroughness in investment analysis,

recommendations & actions

Guidance-Reasonable Basis

 Level of research for due diligence depends on product/service offered

 Prior to making recommendation or investment action consider;

 Firm’s financial results, operating history & business cycles stage

 Mutual fund’s fee & past performance

 Limitation of any quantitative methods used

 Appropriateness of peer group comparisons

Guidance-Using Secondary or Third-Party Research

 To periodically review quality of third party research use the following:

 Review assumptions used

 How rigorous was the analysis

 How timely the research is

 Evaluate objectivity & independence of recommendations

Guidance-Quantitative Research

 Able to explain the nature of quantitative methods used

 Consider scenarios which are not typically used to assess downside risk

 Ensure that both positive & negative results have been used

Guidance-External Advisers

 Ensure advisors have adequate compliance and internal controls

 They present correct return information

 Do not deviate from stated strategies

Recommended Procedures for Compliance

 Policy requiring that research reports, credit ratings & investment recommendations have a reasonable & adequate basis

 Develop written guidance for analysts, supervisory analysts & review committees

 Develop measureable criteria for research report quality assessment

 Written guidance for computer-based models used in developing rating & evaluating financial instruments

 Develop measurable criteria for assessing outside providers

 Standardized criteria for evaluating the adequacy of external advisers

5 A Diligence & Reasonable Basis

Guidance-Group Research & Decision Making

If the group research has a reasonable basis, do not refuse to

be identified with the report merely on the basis of disagreement with the consensus view

2.M&C must have a reasonable &

adequate basis for investment analysis, recommendation or action (supported by research &

investigation)

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

5 B Communication with Clients and Prospective Clients

 Always include basic characteristics of security identified

 Distinguish b/w facts and opinions

 Illustrate investment decision making process utilized

 All means of communication should be included not only the research reports

 Communicate any specific risk factors associated with securities

 Clearly communicate potential gains & losses

 Failing to illustrate model’s limitations may be considered as violation

Recommended Procedures for Compliance

Able to supply additional information if requested maintain relevant information

 Maintain records that support conclusion or any investment action

 Such records are property of the firm

 If regulatory requirements do not recommend, keep records for 7 years

 Members who change firms must recreate analysis related documentation – not rely on memory or material created at previous firms

Recommended Procedures for Compliance

Record-keeping is generally firm’s responsibility

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

 If servicing as a board member disclose

 Disclosure of broker/dealer market making activities is included

 Disclosure of holdings in companies that member recommends or clients hold

 Members’ compensation structure, if perceived to gain any client must be disclosed

 Members working in advisory capacity

 Update disclosure in case of significant change in compensation structure

Guidance –Disclosure of Conflicts to Employers

 Give employers enough information to judge the impact of conflict

 Take reasonable steps to avoid conflict  report promptly if they occur

 Prioritize client’s transactions over personal transactions& made on behalf of the member’s firm

 Personal transactions may be undertaken after clients and member’s employers have been given adequate opportunity

 Personal transaction – member is a “beneficial owner”

 Family member accounts should not be disadvantaged to client accounts

 Information about pending trades should not be acted upon for personal gains

6 A Disclosures of Conflicts

Recommended Procedures for Compliance

Special compensation arrangements (bonus, commission etc.) should be disclosed

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

Recommended Procedures for Compliance

 Limited participation in equity IPOs by investment personnel

 Restrictions on private placements for investment personnel

 Establish blackout/restricted periods for investment personnel

 Reporting requirements for investment personnel

 Disclosure of holdings in which the employee has a beneficial interest

 Provide duplicate confirmations of transaction

Guidance

 Must inform employers, clients and prospects of benefits received for referral of customers and clients

 All types of consideration must be disclosed

Recommended Procedures for Compliance

 Encourage firms to adopt clear procedures regarding compensation for referrals

 M&C should update the employer (at least quarterly) regarding nature and value

of referral compensation received The clients should also be notified about approved referral fee programs

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2017, Study Session # 1, Reading # 2

Copyright © FinQuiz.com All rights reserved

7 Responsibilities as a CFAI Member or CFAI Candidate

7 A Conduct as Members and Candidates in the CFA Program

M&C must not:

 Engage in any conduct that compromise reputation or integrity of CFAI or CFA designation

 Violate integrity, validity or security or the CFA examinations

Guidance

 Must not engage in any activity that undermines the integrity of CFA charter

 Standard applies to:

 Cheating in CFA or any exam

 Revealing anything about the contents & topics of exam

 Not following exam related rules & polices of CFA program

 Disclosing confidential exam related information to candidates or to public

 Improperly using the designation

 Misrepresenting information on PCS or CFAI PDP

 Members can express their opinion regarding the CFA exam or program but without disclosing actual exam specific information

 Members voluntarily participating in the administration of the CFA exam must not solicit or reveal information about:

 Exam questions

 Grading process

 Scoring of questions

7 B Reference to CFA Institute, the CFA Designation, and the CFA Program

M&C must not misrepresent or exaggerate the meaning or implication of membership in CFA institute, holding the CFA designation or candidacy in CFA program

Guidance

 Do not over-promise individual competence

 Do not over promise future investment result

 Sign PCS annually

 Pay CFAI membership dues annually

 Do not misrepresent or exaggerate the meaning of the designation

 No partial designation exists

 Acceptable to state candidate successfully completed the program in 3 years ⇒claiming superior ability is not permitted

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2017, Study Session # 2, Reading # 4

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“ASSET MANAGER CODE OF PROFESSIONAL CONDUCT”

THE ASSET MANAGER CODE

 There are six risk components to the asset manager code

 Ethical responsibilities related to six components are:

 Always act ethically & professionally

 Act independently & objectively

 Perform actions using skill, diligence & competence

 Act in best interest of the client

 Communicate with clients on a regular & accurate manner

 Legal & regulatory compliance

PREVENTING VIOLATIONS

Loyalty to Clients Investment Process & Actions

 Put the client’s interest before your own

Take actions that would not cause any harm to the client

 Never engage in market manipulation of security prices

 Fair dealing with all clients

 Thoroughly investigate & research different investment options

Trading Risk Management, Compliance & Support

 Do not trade or cause others to trade on insider information

 Seek best execution for all trades & equitable allocation among clients

 Use soft $ commission to provide products & services that aids the portfolio manager in investment decision making process

 Place client’s trades before your own

 Develop policies & procedures for complying with codes &

standards & regulatory requirements

 Appoint a compliance officer & establish a firm wide system for identifying & measuring manager’s risk position

 Complete & accurate portfolio information disseminated to clients

 Maintain records

 Contingency plan in the event of a natural disaster

Disclosure Performance & Valuation

 Report investment results in an accurate manner without misrepresentation Use fair MV

 Guideline ⇒ follows GIPS

 In order to avoid conflict of interest, transfer the responsibility of valuing asset accounts to an independent third party

 Disclose the following to the client:

 Any information needed to make an informed decision regarding the investment manager or the organization

 Potential conflict of interest

 Any regulatory or disciplinary action taken against the manager or its personnel

 The investment decision-making process & fee schedule

 Discussion about soft $ commission

 Trade allocation procedures & firm-wide risk management processes

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2017, Study Session # 3, Reading # 5

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“THE BEHAVIORAL FINANCE PERSPECTIVE”

1 INTRODUCTION

2 BEHAVIORAL VERSUS TRADITIONAL PERSPECTIVES Traditional VS Behavioral Finance

 Grounded in neoclassical economics

 Individuals are assumed to be rational, risk averse & utility maximizers

 Traditional finance believes in EMH

 Grounded in psychology

 Based on observed financial behavior rather than idealized financial behavior

Classification

Behavioral Finance Micro Behavioral Finance Macro

 Describe decision making process of individuals

 Cognitive errors & emotional biases

Consider anomalies that distinguish market from efficient markets

2.1 Traditional Finance Perspectives on Individual Behavior

 Traditional finance assumes:

 Investors are risk averse & self interested

 Investors make decisions based on utility theory &

revise expectations consistent with Bayes’ formula

 Efficient Markets

2.1.1 Utility Theory and Bayes’ Formula

 People maximize the PV of expected utility subject to their budget constraints

 Expected utility = weighted sum of the utility values of outcomes × Probabilities

 A rational investor make decision based on following axioms of utility theory:

 Completeness ⇒ an individual has well defined preferences & can decide b/w two alternatives

 Transitivity ⇒ as an individual decides according to completeness axiom, an individual decides consistently

 Independence⇒ assumes preference order of two choices combined with third choice maintains the same preference order

 Continuity ⇒Indifferent curves (IC) are smooth & unbroken (continuous)

 Bayes’ formula:

 New information is assumed to update beliefs about probabilities according to Bayes’ formula

 Application of conditional probability

 Assumes that events are mutually exclusive & exhaustive with known probabilities

   ⁄  =   ⁄ 

 

Where P (A/B) & (P (B/A)) = conditional probability of event A, (B) given B, (A)

P (B) = prior probability of event B

P (A) = prior probability of event A

REM = Rational Economic Man

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2017, Study Session # 3, Reading # 5

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2.1.2 Rational Economic Man

 REM:

 Maximize utility given budget constraints & available information

 Selfishly seek the personal utility maximizing decision

 Tries to minimize economic cost

 Govern by perfect rationality, perfect self-interest & perfect information principles

2.1.3 Perfect Rationality, Self-Interest, & Information

 Prefect rationality ⇒ REM is a rational thinker (ability to reason & make beneficial judgments)

 Prefect self interest ⇒ REM is perfectly selfish

 Perfect information ⇒ REM has perfect knowledge of every subject

2.1.4 Risk Aversion Risk Attitudes

Risk Neutral

 Investors who prefer a certain alternative over an uncertain one (same expected value)

 Diminishing marginal utility of wealth (concave utility function)

 Investors are indifferent b/w a certain & uncertain alternative

 Constant marginal utility of wealth

 Linear utility function

 Investors who prefer to invest in uncertain alternatives

 Increasing marginal utility of wealth (convex function)

 Expected utility theory assumes that investors are risk averse (utility functions are concave & diminishing marginal utility of wealth)

 Certainty equivalent ⇒ max sum of money a person would pay

to participate or minimum amount of money a person would accept to not participate in an event with uncertain outcome

2.2 Behavioral Finance Perspectives on Individual Behavior

 Behavioral finance challenges assumptions of traditional finance

on the following grounds:

 Investors may be unable to make decisions based on utility theory & revise expectations consistent with the Bayes’

formula

 Perfect rationality, self interest & prefect information principles’ violation

2.2.1 Challenges to Rational Economic Man

 Bounded rationality ⇒ individual’s choices are subject to knowledge & cognitive limitations

 REM ignores the fact that people can have difficulty prioritizing short term v/s long term goals

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2.2.2 Utility Maximization and Counterpoint

 An IC depicts all possible combination of two goods amongst which an individual is indifferent

 For perfect substitutes (complements), the IC is a line with constant slope (L-shaped)

 IC analysis fails to consider exogenous factors (e.g risk aversion, individual’s circumstances etc)

2.2.3 Attitudes toward Risk

 Risk evaluation depends on the:

 Wealth level

 Circumstances of the decision maker

 Double inflection utility function ⇒ utility function that changes based on level of wealth

 Investors are risk averse at & income levels

 Investors are risk seeking at moderate income levels

 Prospect theory ⇒ Shape of a decision maker’s value function differs for G&L

 Value function is normally concave for gains, convex for losses & steeper for losses than for gains

2.3 Neuro-economics

 Explain how humans make economic decisions under uncertainty

 Neuro-economics explains:

 Overconfidence & market overreaction

 A panicked rather than analytical response after falling market

 Based on expected value & traditional finance assumptions

 Expected utility can vary from person to person (based on the worth assigned by the decision maker)

 Expected value is same for every one (based on price)

3.2 Bounded Rationality

 Subjective expected utility theory ⇒ probability distributions of all relevant variables can be provided by the decision makers

 Bounded rationality & satisfice ⇒ situation where people gather some available information, use heuristics to analyze the information & stop at a satisfactory decision

 Satisficing ⇒ finding an acceptable solution as opposed to optimizing

 Investor takes steps to achieve intermediate goals, as long as they advance the investor towards the desired goals

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3.3 Prospect Theory

 Investors analyze risk relative to possible gains & losses rather than relative to expected return

 Investors are more concerned with the change in wealth & place greater value on a loss than on a gain of same amount

Phases to Making a Choice

 People compute a value function based on potential outcomes

& their probabilities

Where

,  = Potential outcomes

, = Probabilities

W = Probability weighting function

V = Function that assigns a value to an outcome

 The value function states:

 People overreact (underreact) small (mid-sized & large) probabilities events

 People are loss averse

 Preferences are determined by attitudes towards gains &

Codification

Investor combines those outcomes with identical value

Combination

The riskless component of any prospect

is separated from its risky component

Isolation effect⇒ investors focus on one factor or

outcome while eliminating or ignoring others

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4 PERSPECTIVES ON MARKET BEHAVIOR AND PORTFOLIO CONSTRUCTION

 EMH assumes:

 Market participants are REM

 Population updates its expectations as new relevant information appears

 Relevant information is freely available to all participants

4.1 Traditional Perspectives on Market Behavior

4.1.1 Review of the Efficient Market Hypothesis

Traditional finance assumes EMH

Forms of Market Efficiency

 Consistently excess return is not possible using technical analysis

 Reflect all historical price &volume data

 All publically available information

is fully reflected in securities prices

 Excess return on continuous basis is not possible using technical &

Grossman-Stiglitz paradox ⇒prices must offer returns to information acquisition otherwise the market can’t be efficient

4.1.2 Studies in Support of the EMH

4.1.2.1 Support for the Weak Form of the EMH 4.1.2.2 Support for the Semi-Strong Form of the EMH

 Test whether security prices are serially correlated or whether they are random

 Studies conclude that security prices are random, (support weak form of the EMH)

 Event studies

 Announcement of the event (not event itself) appear

to be reflected in prices

4.1.3 Studies Challenging the EMH: Anomalies

4.1.3.1 Fundamental Anomalies 4.1.3.2 Technical

 Investor generates excess return based on some fundamental characteristics of the firm

 Small cap firms appear to outperform large cap firms

 Value stocks appear to outperform growth stocks

 Moving average ⇒ if the short (long) moving avg prices rise above the long (short) avg prices, this is an indication of strength (weakness)

 Resistance level ⇒ price will climb to the resistance level & then reverse direction (act like a ceiling)

 Support level ⇒ floor price (price will move upward after support level reached)

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4.1.3 Studies Challenging the EMH: Anomalies

4.1.3.3 Calendar Anomalies 4.1.3.4 Anomalies: Conclusion

 January effect ⇒ stocks deliver abnormally  returns during the month of January

 Turn-of-the month effect ⇒ stocks earn

returns on the last day & 1st

four days of each month

Markets are neither perfectly efficient not completely anomalous

 Meets investor’s objective & constraints

 Choose from mean-variance efficient portfolios

4.3 Alternative Models of Market Behaviorand Portfolio

Construction

 Behavioral life-cycle theory incorporates:

 Self control bias ⇒ short-term satisfaction to the detriment of long-term goals

 Mental accounting ⇒ people ignore the fact that wealth is fungible (interchangeable) & assign different portions of their wealth to meet different goals

 Framing bias ⇒results in different responses based on how questions are asked (framed)

4.3.1 A Behavioral Approach to Consumption and Savings

 Behavioral assets pricing model adds a sentiment premium (stochastic discount factor) to discount rate

 Required return on an asset = Rf + fundamental risk premium + sentiment premium

 Sentiment premium ⇒ based on analysts’ forecasts

 The dispersion of analysts’ forecasts,  the sentiment premium,  the discount rate & the perceived value of the assets

4.3.2 A Behavioral Approach toAsset Pricing

 Uses of probability-weighting function rather than the real probability distribution

 Investor’s structure their portfolio in layers & composition of each layer is determined by interaction of following five factors

 The importance of the goals

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 Revised version of the EMH that considers bounded rationality, Satisficing&

evolutionary principles

 The competition & adaptable the participants,  the likelihood of not surviving

 Five implications:

 Risk premiums change over time

 Active management can add value

 Consistent outperformance is impossible

 Investors must adapt to survive

 Survival is the essential objective

4.3.4 Adaptive Markets Hypothesis

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2017 Study Session # 3, Reading # 6

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“THE BEHAVIORAL BIASES OF INDIVIDUALS”

2 CATEGORIZATIONS OF BEHAVIORAL BIASES

 Mechanical or physical limitations (statistical, informational processing

or memory errors)

 More easy to correct than emotional biases (moderated)

Behavioral Biases

Cognitive Errors Emotional Biases

 Stem from impulse or intuition

 Emotional biases are difficult to correct

 Result of attitude & feelings

 Can be adapted not moderated (decisions are made that adjust for it rather than reduce or eliminate it)

FMP= Financial Market Participants

 The tendency to cling to one’s previously held beliefs irrationally or illogically

 Closely related to cognitive dissonance ⇒ a conflict b/w beliefs or opinions & reality

 To resolve this dissonance people may seek only selective exposure, selective perception & selective retention

3 COGNITIVE ERRORS

Belief Perseverance Biases Processing Errors

Describe irrational or illogical information processing in financial decision making

 People place more emphasis on information they used to form their original forecast than on new information

 In Bayesian term⇒ people overweight the base rates & under react to new information

3.1.1 Conservatism Bias

 Slow to react new information

 Tendency to hold winners or losers too long

 Cognitive cost ⇒efforts required to analyze new information

  Cognitive cost of new information, underweight new information

Guidance for Overcoming

 Look carefully at new information

to determine its value

 Seek professional advice

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 People tend to look for & notice what confirms their beliefs & undervalue the contradict views

 It is a natural response to cognitive dissonance

3.1.2 Confirmation Bias

 Consider only the +ve information &

ignore –ve information

 May be incorrect screening criteria

 Under-diversified portfolios

 Employees may overweight employer’s stocks

Guidance for Overcoming

 One should seek out information that challenges one’s beliefs

 Get corroborating support

 Do additional research

 If-then heuristic where individuals classify information into subjective categories using heuristics

 In Bayesian terms, investors tend to underweight the base rates &

overweight the new information

3.1.3 Representativeness Bias

i) Base-Rate Neglect

Too little weight to the base rate

ii) Sample Size Neglect

 Incorrect assumption ⇒ small sample sizes are representative of population

 Too much weight to new information

Guidance for Overcoming

 Under reliance on recent performance that results in excessive trading & return

 Use a periodic table of investment returns that ensure diversification over return chasing

Consequences

 Emphasis is on new information

 Use simple classification rather than deal with the mental stress of updating beliefs given complex data (low cognitive cost)

 Bias in which people tend to believe that they can control outcomes, when infact they can’t

 Subjective probability of personal success is

3.1.4 Illusion of Control Bias

 Excessive trading & inferior performance

 Less diversified portfolio

Guidance for Overcoming

 Investors should recognize that investing is a probabilistic activity

 Seek contrary viewpoints

 Keep records including reminders outlining the rationale behind each trade

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 Individuals perceive outcomes (past

events) as reasonable & expected

 People overweigh their predictions

because they are biased by the knowledge of what actually happened

Guidance for Overcoming

 Carefully record & examine investment decision

 Markets move in cycles so expectations must be managed

 Investment managers must be evaluated relative to appropriate benchmarks

 Individual seem to be anchored to a

value or number & then adjust the number to reflect new information

3.2 Information-Processing Biases

Investors tend to remain focused on &

stay close to their original forecasts

Guidance for Overcoming

 Less weight to historical information

 Look at the basis for any recommendations

 Individual place each goal & the

wealth, that will be used to meet each goal, into a separate mental account

3.2.2 Mental Accounting Bias

Guidance for Overcoming

 Create a portfolio strategy taking all assets into consideration

 Total return consideration

3.2.1 Anchoring and Adjustment Bias

 Bias in which a person answers a

question differently based on the way

in which it is asked

 Narrow framing ⇒ investors use too

narrow a frame of reference

3.2.3 Framing Bias

 More risk averse when presented with a gain frame & more risk seeking when presented with a loss frame (sub optimal portfolios)

 Excessive trading

Guidance for Overcoming

 Investors should focus on expected return & risk rather than on gain or losses

 When interpreting investment situations, investor should be neutral

& open minded

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 Bias in which people estimate the

probability of an outcome based on how easily the outcome comes to mind

 Easily recalled outcomes are

perceived as being more likely

Guidance for Overcoming

 Follow a long-term strategic approach

 Construct a suitable portfolio through developing an IPS rather than relying

on more readily available information

Categorization

Individual categorize information using classification they are most familiar with

Sources of Availability Bias

Narrow Range of Experience

Limited experience of investor will lead

to narrow focus to frame information

Retrievability

 Refers to how easily an idea is

recalled

 The easier to retrieve a memory, the

more likely the individuals will use it

Individuals tend to estimate other’s choices using their own choices

3.3 Cognitive Errors: Conclusion

Systematic process to describe problems & objectives, to document decisions & the reasoning behind them& to compare the actual outcomes with expected results will help to reduce cognitive errors

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4 EMOTIONAL BIASES

 Harder to correct for than cognitive errors

 Recognize these biases & adapt to them

 Individuals focus on potential gains &

losses relative to risk rather than

returns relative to risk

 Disposition effect ⇒ holding losing

positions too long & selling gaining

positions too quickly

4.1 Loss-Aversion Bias

 Hold investments in a loss (gain) position longer (shorter) than justified

by fundamental analysis

 Limited upside potential

 Excessive trading & riskier portfolio holdings

 Framing & loss aversion biases may affect FMPs simultaneously

 House money effect ⇒ investors view profits as belonging to someone else & become less risk averse when investing it

 Myopic loss aversion ⇒ investors overemphasize short-term gains &

losses & weight losses more heavily than gains

 Combine aspects of time horizon based framing, mental accounting & loss aversion

 Higher than theoretically justified short-term equity risk premium

 If frequency of evaluation is , the probability of observing a loss

is 

Guidance for Overcoming

 Disciplined approach of investment based on fundamentals

 Base investment decisions on expectations rather than past performance

 People feel they know more than they

do because they feel they have more

or better information or better at interpreting information

 Too narrow confidence intervals

 Poorly diversified portfolios

ii) Certainty Overconfidence

 Assign too high probabilities to outcomes

 Excessive trading

i) Prediction Overconfidence 4.2 Overconfidence Bias

Self-attribution bias ⇒combination of self enhancing bias (propensity

to claim too much credit for success) & self-protection bias (place failure blame to someone or something else)

Consequences Guidelines to Overcome

 Return than market

 Review trading records & calculate portfolio performance

 Investors should be objective

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 Individuals fail to balance the need for

immediate satisfaction with long-term goals

 Suboptimal saving-consumption

patterns

 Hyperbolic discounting ⇒ human

tendency to prefer small payoff now compared to larger payoffs in the future

4.3 Self-Control Bias

 Insufficient savings for the future

 Accept too much risk by putting capital base at risk

 Asset allocation imbalance problem

Guidance for Overcoming

 Proper investment plan should be in place

 Budgets help deter the propensity to over consume

 Individual’s tendency to stay in their

current allocation rather than make value enhancing changes

 Outcome of the bias may be similar to

endowment & regret aversion bias but reasons differ among these biases

4.4 Status Quo Bias

 Portfolio risk characteristics may differ from investors’ circumstances

 Fail to explore other opportunities

Guidance for Overcoming

 Education about risk, return &

diversification

 Proper asset allocation

 One of the more difficult biases to mitigate

Bias in which people value an asset more

when they hold the rights to it than

when they don’t

4.5 Endowment Bias

 Fail to replace certain assets when it is necessary

 Inappropriate asset allocation

 Investors hold familiar assets

Guidance for Overcoming

 Inherited cash should be carefully invested

 Research familiar as well as unfamiliar assets the investor may not hold

 Familiar assets can be replaced gradually rather all at once

 Regret can arise from taking or not

taking action

 Error of commission ⇒ investor feel

regret from taking an action

 Error of omission ⇒ investor feels

regret for not taking action

 Regret aversion can initiate herding

behavior (invest in similar fashion & in the same stocks as others)

4.6 Regret-Aversion Bias

 Too conservative attitude ⇒ long term under performance & potential failure to reach investment goals

 Herding behavior

Guidance for Overcoming

 Education is primary mitigation tool

 Efficient frontier research & proper asset allocation

4.7 Emotional Biases: Conclusion

 Focus should be on cognitive aspects of the biases than trying to alter an emotional response

 Education about portfolio theory can be helpful

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5 INVESTMENT POLICY ANDASSET ALLOCATION

Two approaches to incorporate behavioral finance considerations into

an IPS are:

Approaches

Goal-Based Investing Approach 5.1 Behaviorally Modified Asset Allocation

 Identify an investor’s specific goals & associated risk tolerance

 Investors are assumed to be loss averse rather than risk averse

 More attractive approach for investors⇒ focused on wealth

preservation

 Riskier than appropriate asset allocation

 Diversification but not efficient portfolios from a traditional finance

perspective

 Risk may better understand but correlations among investments

are not considered

 Standard asset allocation program ⇒ rational portfolio allocation (ignores behavioral biases)

 Investor’s interest ⇒ asset allocation that suits the investor’s psychological preferences

 In creating a modified portfolio:

 Distinguish b/w emotional & cognitive biases

 Consider investor’s wealth level

 If a bias is adapted, the resulting portfolio represents an alteration

 Wealthier the client, more likely it is

to adapt the biases

 Decision to moderate or adapt biases depends on the type of behavioral bias

 Cognitive errors ⇒ moderated

 Emotional biases ⇒ adapted

5.1.1 Guidelines for Determining a Behaviorally Modified Asset Allocation

 Wealth is determined based on level of assets & lifestyle

 Standard of living risk ⇒ risk that a specified life style may not be sustainable

5.1.2 How Much to Moderate or Adapt

 To modify an allocation, no of asset classes used in the allocation is important consideration

 Least (most) adjustment to the rational portfolio ⇒ low (high) wealth level client with cognitive bias (emotional bias)

 Middle of the road ⇒ high (low) wealth with cognitive (emotional) biases (need to both adapt & moderate behavioral biases)

 Market participants may move up or down on efficient frontier after considering client’s behavioral make up

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2017 Study Session # 3, Reading # 7

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“BEHAVIORAL FINANCE AND INVESTMENT PROCESSES”

2 THE USES AND LIMITATIONS OFCLASSIFYING INVESTORS INTO TYPES

 Risk own capital to gain wealth

 Prefer to maintain control of own investments

  Risk tolerance

2.1 General Discussion of Investor Types

Models of Investor Psychographics

2.1.1 Barnewall Two-Way Model 2.1.2 Bailard, Biehl, and Kaiser Five-Way Model

(classify five investor personalities along two axes) Passive Investors Active Investors

 Investors who have become

wealthy passively

 Risk averse and have a

greater need for security

 Whether then investor is methodical, careful &

analytical in his approach to life

 Method of action can range from carful to impetuous

Confident axis Careful-impetuous axis

 How confidently investor approaches life

 Emotional choices

Five Investor Personality Types

 Might hold highly concentrated portfolios

 Willing to take chances & likes to make own decisions

 Advisors find them difficult to work with

 Like to be the center of attention

 Might have opinions but recognizes limitations

 Willing to seek & take advice about investing

 Confident & careful

 Listen & process information rationally

 Likes to make own decisions after careful analysis

 Cautious & concerned about the future

 Concerned about protecting their assets

 Seek advice of someone they perceive as more knowledgeable

The Straight Arrow

 Sensible & secure

 Willing to take  risk for  expected return

Two Methods

 Test for all behavioral biases in the client

 Create an appropriate IPS & behaviorally modified asset allocation

 May be time consuming or complex

 Called behavioral alpha approach

 Simple & more efficient than a bottom-up approach

 Determine type of bias in the client & how to correct for

or adapt to the biases

2.1.3 Behavioral Finance and Investment Processes Behavioral Investor Types

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Step in Top-Down Approach

 Step 1 ⇒ interview the client & identify active or passive traits & risk tolerance

 Step 2 ⇒ the investor on the active/passive & risk tolerance scale

 Step 3 ⇒ tests for behavioral biases

 Step 4 ⇒ Classify investor into a behavioral investor type

Passive Preserver (PP)

 Low risk tolerance & are subject to emotional biases

 Emphasis on financial security & preserving wealth

 Most common emotional biases to PPs:

 Endowment, loss aversion, status quo & regret aversion

 Cognitive errors:

 Anchoring & adjustment & mental accounting

Advising Passive Preserver

 Difficult to advice (driven mainly by emotion)

 Receptive to “big picture” advice

Friendly Follower (FF)

 Passive investors with low to medium risk tolerance

 Cognitive biases

 Prefer popular investments

 Overestimate risk tolerance

 Influenced by availability, hindsight, framing & regret aversion biases

Advising Friendly Followers

 Difficult to advise (overestimate their risk tolerance)

 Education is usually the best course of action (cognitive errors)

Independent Individualist

 Active investor with medium to high risk tolerance

 Strong willed & independent thinker (maintain their opinions)

 Most likely to be contrarian & typically subject to cognitive errors

Advising Independent Individualists

 Difficult to advice but usually willing to listen to sound advice

 Regular educational discussion is effective

Active Accumulator

 Active investor with high risk tolerance

 Most aggressive investors & primarily subject to emotional biases

 Quick decision makers with risky investments

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Advising Active Accumulator

 Most difficult client to advise (like control)

 May lack self control

 Best approach to deal ⇒ take control of the situation

2.2 Limitations of Classifying Investors into Various Types

 Individuals may simultaneously display both emotional & cognitive biases

 Might display traits of more than one behavioral investor type

 As investors age, they will most likely go through behavioral changes

 Two individuals with same behavioral investor type are likely to require unique treatment

 Individuals, tend to act irrationally at unpredictable time

3 HOW BEHAVIORAL FACTORS AFFECT ADVISER- CLIENT RELATIONS

 Goal of the client/adviser relationship ⇒ construct a portfolio with which a client is comfortable

 Portfolio should serve the client’s longer term goals

 BF can enhance the following important areas of every successful advisory relationship

3.1 Formulating Financial Goals

BF helps adviser to understand the reasons for the client’s goals

3.2 Maintaining a Consistent Approach

BF adds structure & professionalism to the relationship

3.3 Investing as the Client Expects

 Area that can be most enhanced by incorporating BF

 Adviser is fully awared of what actions to perform &

what information to provide

3.4 Ensuring Mutual Benefits

Incorporating BF into client/adviser relationship act as a closer bond b/w them

3.5 Limitations of Traditional Risk Tolerance Questionnaires

 Risk tolerance questionnaires:

 Ignore behavioral issues

 Can generate different results when applied repeatedly

 May not be revised

 Adviser may interpret the results of such questionnaire too literally

 May work better for institutional investors

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4 HOW BEHAVIORAL FACTORS AFFECTPORTFOLIO CONSTRUCTION

BB affects how investors construct portfolio from the securities available

to them

4.1 Inertia and Default

 In most DC plans members show inertia & do not ∆ their asset allocation

 Target date funds ⇒ fund that automatically switch from risky assets to fixed income assets as the plan member nears the intended retirement date

 Standardized strategy (one size fits all solution)

4.3 Company Stock: Investing in the Familiar

 Reasons why employees have a tendency to invest in their company’s stocks:

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5 BEHAVIORAL FINANCE AND ANALYST FORECASTS

 Undue faith in forecasting ability

 Several behavioral biases that contribute to overconfidence:

 Illusion of knowledge bias

 Self attribution bias

 Representativeness bias

 Availability bias

 Hindsight bias

5.1 Overconfidence in Forecasting Skills

 Self calibration ⇒ process of remembering previous forecasts more accurately

 Well structured feedback, unambiguous forecasts &

systematic review process can reduce hindsight bias

 Counter arguments, appraisal by colleagues, superiors as well

as self appraisal can help to control overconfidence

 Incorporate additional information with a Bayesian approach

5.1.1 Remedial Actions for Overconfidence and Related Biases

 The way a company’s management frames information can influence how analysts interpret it & include it in their forecasts

 Three cognitive biases frequently seen when management reports company results:

5.2 Influence of Company's Management on Analysis

 Biases are usually related to analysts collecting too much information some biases are:

 Illusion of knowledge & control

5.3 Analyst Biases in Conducting Research

 Focus on more objective data

 Collect information in a symmetric way

 Assign probabilities to base rates

 Consider the search process, limits& context of information

 Prompt feedback & document decision making

5.3.1 Remedial Actions for Analyst Biases in Conducting Research

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 In a group setting, the individual biases mentioned before can be either diminished or amplified with additional biases being created

 Social proof bias ⇒ bias in which individuals are biased to follow the beliefs of a group

 Typically a group will have more confidence in its decisions (leads to overconfidence bias)

6 HOW BEHAVIORAL FACTORS AFFECTCOMMITTEE DECISION MAKING

 Committee decision can be improved by carefully analyzing

& learning from past decisions & good quality feedback

 Changing committee membership can be unhelpful

6.1 Investment Committee Dynamics

 Committee should be made up of members from diverse backgrounds

 Ensure professional respect & analysts self esteem

 Collect individual views in advance of discussion (can suppressed privately held information)

6.2 Techniques for Structuring and Operating Committees to Address Behavioral Factors

 Anomalies are identified by persistent abnormal returns that differ from zero & are predictable in direction

 Some apparent anomalies may be explained by:

 Small sample involved

 Selection or survivorship bias

 Data mining

7 HOW BEHAVIORAL FINANCEINFLUENCES MARKET BEHAVIOR

 Momentum effect ⇒ pattern of returns that is correlated with the recent past

 Return are +vely correlated in short term (up to 2 years) &

-vely correlated in long term (revert to the mean)

 Several forms of Biases

 Herding

 Availability bias (extrapolate trends)

 Hindsight bias (trend chasing effect)

 Disposition effect (mean reversion at longer periods

of three to five years)

7.2 Momentum

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 Bubble & crashes ⇒ respectively periods of unusual +ve or –ve return

 Bubbles typically develop more slowly relative to crashes (due to difference in behavioral factor involved)

 A no of cognitive & emotional biases during such periods are:

7.3 Bubbles and Crashes

 Studies have identified that the value stocks have outperformed relative

 Overconfidence in predicting growth rates (growth stocks over valuation)

 Home bias anomaly ⇒ investors favor investing in domestic country as compared to foreign countries

7.4 Value and Growth

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“MANAGING INDIVIDUAL INVESTOR PORTFOLIOS”

3 INVESTOR CHARACTERISTICS

 Categorizing individual investors based on their situational characteristics

 Investor’s basic philosophy & preferences that facilitate the

discussion of investment risk with the investors

CF = Cash Flow

3.1 Situational Profiling

Approaches of Situational Profiling

 Manner of acquiring wealth offers insight into an investor’s

risk attitude

 Active investors (e.g successful entrepreneurs) exhibit a

higher level of risk tolerance

 Reluctant to cede control to a third party

 Passive recipients of wealth (e.g inherited wealth) may be

associated with reduced willingness to assume risk

 If investor perceives his holdings as small (large), may demonstrate a low (high) tolerance for portfolio volatility

 Low return (high return) portfolio as compared to lifestyle is

considered small (large)

 Very few investable assets

ii) Accumulation Phase

 Income accelerates & gradually reaches its peak

 Risk tolerance, wealth &

long-term time horizon

iii) Maintenance Phase

 Individual moves into the later

years of life

 Risk tolerance & time horizon

 Goal ⇒ preserving wealth

iv) Distribution Phase

 Accumulated wealth is

transferred to other persons or entities

 Tax constraints & transfer

strategies often become important consideration

SAA = Strategic Asset Allocation

MCS = Monte Carlo Simulation

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