Jul 24

Does Your Manager Follow the CFA Asset Manager Code of Professional Conduct?


Before we answer that question, let’s start with what the Asset Manager Code of Professional Conduct is. According to the CFA Institute:

“The Asset Manager Code of Professional Conduct outlines the ethical and professional responsibilities of firms (“Managers”) that manage assets on behalf of clients. By adopting and enforcing a code of conduct for their organizations, Managers demonstrate their commitment to ethical behavior and the protection of investors’ interests.”

It outlines general principles of conduct, and includes more details, covering: nbsp&;
– Loyalty to Clients
– Investment Process and Actions
– Trading
– Risk Management, Compliance and Support
– Performance and Evaluation
– Disclosures

On the CFA Institute’s web site, you can view a summary of the Code and a more detailed document explaining the Code.

Importantly, this second edition of the code is now four years old, and provides an opportunity for investment managers to self-identify as being in compliance with it. How many of the top ten insurance asset managers have self-identified as being in compliance?

Here’s a list of the top 10 (in assets, as ranked by Insurance Asset Manager) who have self-identified as complying with the Code:


And, now, as of today per the CFA website, the top 10 who have NOT self-identified as complying with the Code:

Deutsche Asset Management
Wellington Management
Delaware Investment Advisors
Gen Re-New England Asset Management
Goldman Sachs Asset Management
Western Asset Management
JP Morgan Asset Management

Of course, those managers who have not formally self-identified as complying, may still be complying with the Code. In fact, we would be shocked if this was not the case. Or, perhaps there is a laundry list of legal reasons why a manager has not self-identified?

Nonetheless, the next time you speak with your manager, perhaps a question should be: “Why have you not self-identified as being compliant with this Code of Professional Conduct?”

And more importantly, “Do you comply with the Code? And, if you do, could you please certify annually as such to our Board?”

Certainly, the CFA Asset Manager Code of Professional Conduct is a document to which most managers would comply. However, obtaining an annual certification of such can go a long way to providing additional peace of mind for your insurer.