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Propose firm policies and procedures that stop breaches of the Asset Manager Code from occurring

CFA® Level III · Ethical and Professional Standards · Asset Manager Code of Professional Conduct · L3.ET.10.d

The idea

Prevention starts before the claim is made: a gap analysis of every provision against current practice, closing each gap before notifying CFA Institute. Then appoint a compliance officer with the independence and authority to act, and write policies on personal trading, gifts, trade allocation, best execution, soft commissions, valuation and proxy voting. Have custodians send statements directly to clients so holdings are confirmed independently, use independent pricing with a documented fair-value process for illiquid assets, and test the business continuity plan regularly. Train staff every year, monitor adherence, and revisit the policies whenever the business or the law changes. A good recommendation links each control to the provision it secures and explains how the firm will check that it works.

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