Standard V(A): Diligence and Reasonable Basis
KnownMemorizeStandard V(A): what to know cold
| Situation | What you must do |
|---|---|
| Your own recommendation | Exercise diligence, independence and thoroughness; have a reasonable and adequate basis backed by research |
| Secondary (same firm) or third-party (outside firm) research | Make reasonable efforts to confirm it is sound. Check assumptions, rigor, timeliness, objectivity and independence |
| Quantitative model | Understand its assumptions and limitations; test it before use, including extreme scenarios |
| External adviser / subadviser | Review as carefully as a security: code of ethics, compliance and controls, return data quality, process and adherence to strategy |
| Group report you disagree with | Stay on it if the consensus has a reasonable basis and is independent and objective. You may document your dissent |
| Outcome | A bad result after a diligent process is not a violation |
Memory hook Trust, then verify: who wrote it, what did they assume, how hard did they look, is it current, are they independent?
Know it cold No reasonable basis (thin sources, unchecked research, untested model) = violation. A sound process that still loses money = no violation.
Key terms
- diligence Memorize
- reasonable basis Memorize
- third-party research Memorize
- quantitative models Use it
- external advisers Use it
- group research Use it
- dissenting opinion Use it
- Your own research Use it filings, management calls, industry and macro context
- Others' research Memorize
- Secondary research done by someone else in your firm
- Third-party research done outside the firm, such as a broker
- Check assumptions, rigor, timeliness, objectivity and independence
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- Quantitative models Use it
- Understand assumptions and limitations
- Test before use including extreme scenarios
- Developers owe a higher level of diligence than users
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- External advisers Use it
- Code of ethics
- Compliance and internal controls
- Quality of reported returns
- Process and adherence to strategy
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