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
Trang 12017 Study Session # 1, Reading # 1
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“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
Trang 22017 Study Session # 1, Reading # 1
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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
Trang 32017, Study Session # 1, Reading # 2
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“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
Trang 42017, Study Session # 1, Reading # 2
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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
Trang 52017, Study Session # 1, Reading # 2
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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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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)
Trang 72017, Study Session # 1, Reading # 2
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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
Trang 82017, Study Session # 1, Reading # 2
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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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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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Guidance
If a client is involved in illegal activitiesmembers 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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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)
Trang 122017, Study Session # 1, Reading # 2
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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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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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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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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
Trang 162017, Study Session # 1, Reading # 2
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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
Trang 172017, Study Session # 1, Reading # 2
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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
Trang 182017, 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
Trang 192017, 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
Trang 202017, 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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“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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“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