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- 2014-7-1
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What you want to know about ETHICS
Ok guys, by now many have read some of my posts. I hope they are helpful. I did see a previous error in my quant post. I miscalculated Root Mean Squared Error: RMSE, which is used for out-of-sample forecast error. I forgot that the denominator is simply n-k-1. Essentially, RMSE is the square root of MSE on the Anova table, which is the sum of squared errors (SSE) divided by n-k-1.
Ok, good. Onto ethics.
Last, you of course want to doublecheck my information for accuracy. I'm not omniscient, far from it actually.
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In Ethics, I'm going to list some of the concepts that I found were not intuitive. In other words, I think you'll get the intuitive, common-sense concepts. However, I think these areas are more testable.
<<<<<<<<<CODE AND STANDARDS>>>>>>>>>>>>
1(a) Knowledge of the Law - comply with the stricter law (Code & Standards vs local securities regulation), dissociate from violations and this can mean quitting your job, keep current on compliance laws via continuing ed., firms should develop a written Code of Ethics.
1(b)Independend & Objectivity - create a firmwide restricted list during quiet periods, corporate reimbursement for analyst air travel not permitted, limit use of corporate aircraft unless other transportation unavailable, limit gifts, strictly limit candidate and member IPO participation.
1(d)Misconduct - personal Bankruptcy not a violation unless circumstances involve fraud or deceit.
2(a)Material Nonpublic Info - an analyst conference call is NOT public dissemination of information, but a news conference IS. Remember the mosaic theory, if you figure out a potential acquisition because you're just smart, good for you, just document it!
3(b)Fair Dealing - develop a written trade allocation policy for trades that don't fill completely, disclose different levels of service (different levels of service are not a violation).
3(d)Performance Presentation - present the performance of the weighted composite of similar portfolios rather than a single account.
4(b)Additional Compensation Arrangements - get written consent for any gifts, benefits, etc that might compete with employer.
5(a)Diligence and Reasonable Basis - within group analyst research recommendations, a member should document a difference of opinion, relative to the research recommendation, with team members.
6(b)Priority of Transactions - do not participate in private placements, establish blackout and restricted periods, IPO participation should be pre-cleared even where there is no conflict of interest and no participation in over-subscribed IPOs or limited offerings.
<<<<<<<<<<<<<<<<<<<<<<<SOFT DOLLARS>>>>>>>>>>>>>>>>>>>>>
These include principal trades (involving spreads/discounts) and agency trades (commission paid for trade).
Under the Safe Harbor theory, an investment manager can execute a trade with a broker who does not provide the lowest cost as long as the benefit is commensurate with the cost.
Mutual funds boards are the client when determining the benefits of brokerage for mutual fund managers.
Agency Trades - client brokerage CAN benefit other clients as long as, over time, that client receives a benefit from other client brokerage.
Principal Trades - as long as the trade is not subject to fiduciary recommendations (ERISA, etc.), client brokerage can benefit other clients with PRIOR consent from the said client.
*Client brokerage can be used to pay for services like the Bloomberg terminal as long as the client's account receives a benefit from that service. Should be documented.
<<<<<<<<<<<<<<<<<<<Research providers>>>>>>>>>>>>>>>>>>>>>
Research analysts must not be allowed to communicate to the researched firm anything other than factual information before the research report is published.
Employees and MEMBERS OF THEIR IMMEDIATE FAMILIES (defined as those living in the same primary residence) are prohibited from front-running, trading during blackout periods, restricted list trading, etc.
<<<<<<<<<<<<<<<<<<<<<<<Old Prudent Man vs New Prudent Investor>>>>>>>
Old Man
-certain investments not allowed for trusts
-each investment must be prudent
-no delegation allowed
-investing in mutual funds is imprudent
New Investor
-diversification required
-investment decision made on RISK and RETURN analysis
-duty to avoid excessive fees, costs, etc.
-duty of impartiality requires balancing current income and growth
-duty to delegate if prudent |
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