CASE STUDYETHICS IN PRACTICE: 2019 CFA Institute.

All rights reserved. You may copy and distribute this content, without modification and for non-commercial purposes, provided you attribute the content to CFA Institute and retain this copyright notice. This case was written as a basis for discussion and is not prescriptive of how a business situation or professional conduct matter should or should not be handled or addressed. Certain characters mentioned are fictional to facilitate discussion, and any resemblance to actual persons is coincidental.Back to ContentsOReilly is chief financial officer of Global Strategic Partners (GSP), a global investment adviser that merged with Holland Advisers, a smaller regional investment adviser. As a result of the merger, GSP becomes the adviser of record for several thousand Holland clients. For a period following the merger, GSP maintains Hollands legacy billing system for original Holland clients until those clients can be converted to GSPs billing system and platform. When the Holland billing system is converted, OReilly reviews the client billing information to ensure that it is correctly copied into the GSP billing system. Unbeknownst to OReilly, Hollands billing system has a number of billing inaccuracies. For instance, Hollands billing system inadvertently causes client advisory fees to default to the highest available account fee when client accounts in one advisory program are transferred between branches. Also, Hollands billing system charges outside manager fees on assets that are held in money market accounts that do not use an outside manager. Finally, Hollands billing system does not reimburse advance-billed fees when clients terminate their accounts. Some of these fee billing errors resulted from coding or other systems errors, whereas others were caused by administrative errors, including the failure of Holland personnel to immediately input negotiated lower fee rates into the billing system. As chief financial officer of GSP, OReilly

A. is not responsible for inadvertent billing system errors by Holland before the merger.

B. fulfills his responsibilities by reviewing client billing information for Holland clients to ensure that it is correctly copied into the system.

C. fails to meet his ethical responsibilities to his firms advisory clients

.D. acts appropriately as long as he remedies Hollands billing errors once the client accounts are converted to GSPs billing system and platform.

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