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Asset Manager Code

Overview

The CFA Institute Asset Manager CodeTM (the Code) outlines the ethical and professional responsibilities of firms that manage assets on behalf of clients. The principles and provisions address six broad categories: (1) loyalty to clients, (2) investment process and actions, (3) trading, (4) risk management, compliance, and support, (5) performance reporting and valuation, and (6) disclosures.

Why Is It Important?

The Code outlines the ethical and professional responsibilities of firms that manage assets on behalf of clients. It provides standards and supportive guidance based on general principles of conduct.

The Code states that managers have these responsibilities to their clients:

  • To act in a professional and ethical manner at all times
  • To act for the benefit of clients
  • To act with independence and objectivity
  • To act with skill, competence, and diligence
  • To communicate with clients in a timely and accurate manner
  • To uphold the rules governing capital markets

Why Should Firms Comply with the Asset Manager Code?

Many firms have their own conduct standards in place to guide their work, but it can be difficult for clients to compare different codes and identify key differences in the firm's level of commitment toward protecting their interests. Rather than evaluating each firm's code of conduct separately, clients can use the CFA Institute Asset Manager Code to quickly identify firms that commit to a common foundation of ethical principles. Adopting the Code isn't an "either - or" proposition; some managers already comply simply on the strength of their existing code of ethics.

How Can I Comply with the Asset Manager Code?

Your organization may already have a code of ethics in place that addresses or goes beyond the principles and provisions in the CFA Institute Asset Manager Code. Provided your code is consistent with ours, you do not need to amend your existing code to comply with the CFA Institute code.

  1. Review your organization's existing code of ethics, policies, and procedures in comparison to the Code and identify possible gaps or differences.

  2. Refer to the Appendix: Recommendations and Guidance (PDF) and review the interpretations and additional guidance (PDF) to help you determine whether your organization's procedures comply.
  3. Make revisions, as needed, to align with the Code.
  4. Complete and submit the claim of compliance form before claiming compliance for the first time. Subsequently, asset managers must submit a notification form on an annual basis by 30 June of each year with information as of the most recent 31 December.
Consider the Regulatory Compliance Association’s “Compliance Transparency Platform – Implementing the CFA Institute Asset Manager Code,” a third-party tool for reviewing compliance by your organization.

Tools and Resources

These resources can be used to assist you in reviewing and mapping your existing policies to the principles of the Asset Manager Code. Sample policies, procedures, and forms are provided as examples of the policies and language that can be used.

Implementation and Assessment Guide (PDF)

Sample Policies and Procedures (DOC)

Sample Forms (DOC)

Cross-reference Mapping Tool (DOC) and Cross-reference Mapping Template Grid (XLS)

 

Translations

The Code is a high-level, two-page summary of the principles and requirements of the Asset Manager Code. Recommended Guidance provides you more details about how to interpret the Code.

All of the following are PDF documents.

Arabic The Code | Recommended Guidance 
Chinese The Code | Recommended Guidance 
Czech The Code
English The Code | Recommended Guidance 
French The Code | Recommended Guidance 
German The Code | Recommended Guidance 
Greek The Code |
Indonesian The Code | Recommended Guidance 
Italian The Code | Recommended Guidance 
Japanese The Code | Recommended Guidance 
Korean The Code | Recommended Guidance 
Mongolian The Code |
Portuguese The Code | Recommended Guidance 
Russian The Code | Recommended Guidance 
Spanish The Code | Recommended Guidance 
Thai The Code | Recommended Guidance 
Vietnamese The Code |

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