Guerriere Capital Management is a private equity fund of funds with investment vehicles
that (1) invest in other private equity funds and (2) co-invest alongside private equity
funds directly in underlying companies. Guerriere has adopted the CFA Institute Asset
Manager Code of Professional Conduct and notified the CFA Institute. Guerriere
appointed a current employee at the firm, Alex Dziadosz, CFA, as chief compliance
officer. Dziadosz also retains his duties to underwrite potential funds and coinvestments.
19. Which of the following best describes Guerriere’s appointment of a compliance
officer?
A. The Asset Management Code of Conduct does not require the
appointment of a compliance officer.
B. The Asset Management Code of Conduct allows for a chief compliance
officer who is an employee of the firm.
C. The appointment of Dziadosz as the chief compliance officer violates the
Asset Management Code of Conduct because of his other duties at the
firm.
I understand that the firm can appoint a current employee as a compliance officer. But he should be independent. Here, the employee is still retaining his duties at the firm. Should’nt the answer be option C ?
As per the Asset Manager Code, Compliance officer may be an existing employee as well. Where possible, he should be independent from “investment and operational personnel” and should directly report to the CEO or Board.