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On his first day at Karibe, the firm asks Somer to approve marketing materials that present the following performance disclosures. Text which states: Somer has
On his first day at Karibe, the firm asks Somer to approve marketing materials that present the
following performance disclosures.
Text which states: Somer has generated average annual returns of
The year performance of a composite of Karibe client accounts that follow a similar
smallcap value strategy
A disclosure that the assumptions and calculations underlying the returns presented are
publicly available on Karibes public website
To maintain relationships with clients and to attract prospective clients, Somer is active on
social media. He posts a link to a news story about a famous athlete who recently paid
substantial tax penalties after failing to properly report investment gains. In addition to the link
Somer writes the comment: A client of mine had similar gains, but because I kept proper
records he faced no penalties. #HireAProfessional Some responses to the post suggest that
readers mistakenly believe the athlete is Somers client. Somer does not post a clarifying
comment.
Somer develops a new quantitative investment strategy that he describes in marketing
materials. The description states that the strategy is based on eight proven fundamental and
technical factors, including wellknown factors such as value and momentum as well as certain
proprietary factors that have been backtested. The strategy includes a dynamic weighting
component to adjust the amount allocated to each factor based on prevailing market
conditions. The materials also highlight risks such as the possibility that the model or its
underlying factors may not work out of sample, and because the weight placed on various
factors is dynamic, it may not be suitable for clients who seek steady exposure to certain
factors. One of Somers clients agrees to use this strategy. When preparing the first
performance report for this client, Somer discovers a coding error that reversed the clients
weightings assigned to the value and momentum factors.
Prior to joining Karibe, Somer purchased shares in a smallcap technology firm for his personal
portfolio. When he started his new role Somers disclosed the position, which had quadrupled in
value since the initial purchase and represented more than of his personal holdings. He had
no intention to sell the shares and he recommended them to clients at Karibe, to whom he
disclosed his ownership. After the successful launch of a new product resulted in additional
large gains in the shares, Somer now recommends that clients place limit orders when
purchasing the shares. Though he remains bullish on the stock he is concerned about the size of
his personal position, which is now more than of his portfolio. One of his clients recently
placed a limit order at $ per share, which represents the highest bid in the market. The
lowest offer is $ Somer considers filling the clients order with some of his own shares at the
$ bid price. To best comply with the CFA Institute Standards of Professional Conduct the Standards
related to performance presentation, Somer should modify the:
A text regarding Somers investment returns.
B presentation of the performance for Karibes representative composite.
C content of the disclosure statement related to assumptions and calculations
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