Standard V(C) – Record Retention

Members and Candidates must create and keep relevant documents to support their investment analysis, suggestions, actions, and other investment-related discussions with customers and prospects.

Application: Records of The Firm

Scott Garcia is the head of quantitative research at Green Point Investments. Over the six years at Green Point, he has contributed and developed the firm’s quantitatively driven investment strategies. Garcia has diligently documented the assumptions and reasoning behind his work product. Garcia has resigned and has plans to start a consultancy firm. With the permission of his employer, he copies the records of the supporting documentation of strategies he has previously worked on.

Has Garcia violated Standard V(C) – Record Retention?

1. Yes, because he is not permitted to make copies of any material developed at his previous employer.
2. No, because he received permission to make copies of the supporting documentation.
3. No, because he maintains all documents related to the work on the firm’s investment strategies.

Solution

The correct answer is B.

All the records developed by Garcia are the property of the firm. Garcia has not violated Standard V(C) – Record Retention because he received permission from his employer to make copies of the supporting documentation. If Garcia had not received permission, he would recreate the supporting documentation and strategies through publicly available information.

LOS 5(a): Evaluate practices, policies, and conduct relative to the CFA Institute Code of Ethics and Standards of Professional Conduct.

LOS 5(b): Explain how the practices, policies, or conduct does or does not violate the CFA Institute Code of Ethics and Standards of Professional Conduct.