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. Guerriere’s website noted that it adopted the Code, verified by the CFA Institute for the current year.
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.
Answer should be B. It is clearly mentioned under the AMC that a Compliance Manager must be appointed, the same can be an employee of the firm as well.
but why isnt C the answer
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”. Dziadosz also retains his duties to underwrite potential funds and co-investments – this is a violation.
yes, and that is what is written in option c