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CFA Level II · Ethics & Standards

Asset Manager Code

Section: Asset Manager Code of Professional Conduct Estimated study time: 60 minutes Content: The Asset Manager Code (AMC) is a voluntary set of ethical principles established by CFA Institute specifically for firms that manage assets on behalf of clients. While the Standards of Professional Conduct apply to individual CFA members, the AMC is a firm-level code designed to govern the entire organization's conduct. At CFA Level 2, candidates must understand the six components of the AMC, how they translate into specific firm-level policies, and how to apply them to vignette scenarios involving asset management firms rather than individual advisers. A firm that claims compliance with the AMC must comply with all provisions — partial compliance claims are not permitted. The six components of the Asset Manager Code are: (1) Loyalty to Clients — placing client interests above the firm's and acting as a fiduciary; (2) Investment Process and Risk — using sound and documented investment processes and risk management; (3) Trading — seeking best execution and not disadvantaging clients through trading practices; (4) Risk Management, Compliance, and Support — maintaining robust compliance infrastructure; (5) Performance and Valuation — presenting performance fairly and valuing client portfolios accurately; and (6) Disclosures — providing clients with timely, accurate, and complete information about the firm, its services, fees, conflicts of interest, and risk. Vignette questions may describe a firm's policies and ask whether the firm is in compliance with the AMC. The Loyalty to Clients component at the firm level encompasses acting as a fiduciary in all client relationships, not suborning the firm's interests to client interests through fee structures or product selection, and having policies that govern personal trading by all staff…

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