AMC Flashcards
reimbursement
Bồi hoàn
disbursement
giải ngân
the period of report under AMC
at least quarterly, and when possible, within 30 days of the end of the period
6 provisions (điều khoản) of AMC
A. Loyalty to clients
B. Investment process and actions
C. Trading
D. Risk management, compliance and support (Focus)
E. Performance and valuation
F. Disclosures (Focus)
What AMC required about the compliance
(1) Develop and maintain (a) policies and (b) procedures to ensure compliance with
(2) Appoint a compliance officer responsible for
arcording AMC, what a compliance officer responsible for ?
(1) administering the policies and procedures
(2) investigating complaints regarding the conduct of the manager or its personnel
requirement about compliance officer arcoring AMC
(1) qualities: competent (toàn diện); knowledgable (hiểu biết); credible (đáng tin cậy); is empowered to carry out his/her duties (được trao quyền)
(2) should take steps to implement employee training and conduct continuing
(3) should be charged with reviewing firm and employee transactions to ensure the priority of client interests
how to establish compliance offfice arcoding AMC
depending on the size and complexity of the manager’s operations:
(1) may designate an existing employee to also serve as the compliance officer
(2) may hire a separate individual for that role
(3) may establish an entire compliance department
the report and independent of compliance officer arcoding AMC
(1) should be independent from the investment and operations personnel
(2) should be report directly to the CEO or BOD
arcoding AMC, how arquired portfolio info provide to clients
(1) ensure the info is accurate and complete
(2) arrange for independent third-party confirmation or review of such info
arcoding AMC, about BCP, what is minimum requirement ?
(1) adequate backup, preferably off-site, for all account info
(2) alternative plans for monitoring, analyzing and trading investments
(3) plans for communicating with critical vendors and suppliers
(4) plans for employee communication and coverage
of critical business functions
(5) plans for contacting and communicating with clients during a period of extended disruption (Eg: hệ thống VPS lỗi -> phải có email thông báo và xin lỗi KH)
arcoding AMC, how about performance presentation of hypothetical/ back-tested performance ?
Hypothetical or back-tested performance must be clearly identified
what type of price must use to value client holdings arcoding AMC ?
+ fair - market price
+ Apply methods to determine the fair value of any securities in the event of no available independent, third-party market quotation
+ Use independent third-party may overcome conflicts of interest
arcoding AMC, The investment process, including info regarding
(1) lock-up periods
(2) strategies
(3) risk factors
(4) use of derivatives and leverage
how about the return must be diclosed arcoding AMC
at a minimum, manager should provide clients
(1) gross and net-of-fees returns
(2) disclose any unusual expenses