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The Management of Investment Decisions
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3. Prepare investment policy statement. LEVEL 1 ASSESSMENT LEVEL 1 ASSESSMENT LEVEL 1 ASSESSMENT LEVEL 1 ASSESSMENT
4. Use “prudent experts” (Investment Managers) ORGANIZE FORMALIZE R Risk Tolerance Self-Assessment of
Fiduciary Excellence
for Investment Managers
Self-Assessment of
Fiduciary Excellence
for Investment Stewards
Self-Assessment of
Fiduciary Excellence
for Investment Advisors
Self-Assessment of
Fiduciary Excellence
5. Control and account for investment expenses. Organizations that manage separate
accounts, mutual funds, unit trusts,
and commingled trusts.
Persons who serve as trustees of personal
trusts and investment committee members
of retirement plans, foundations, and
endowments.
Persons who provide comprehensive and
continuous investment advice including
financial advisors, broker-consultants,
investment consultants, wealth managers,
financial consultants, trust officers,
The 2006 Pension Protection Act requires
the engagement between the plan sponsor
of a qualified pension plan and a fiduciary
adviser (an adviser who is providing specific
investment advice to participants) to be
A
and financial planners. audited every year by a qualified and
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6. Monitor the activities of “prudent experts.” WORLDWIDE EDITION U.S. EDITION U.S. EDITION U.S. EDITION
Due Diligence Screens for The Hierarchy of Decisions Vertical and Horizontal
Investment Managers Application of Fiduciary
1. Regulatory oversight Practices
Most Level 3 Independent Assessment (CEFEX Certification)
Important What is the time horizon of the investment strategy?
2. Minimum track record
What asset classes will be considered?
3. Stability of the organization
What will be the mix among asset classes? INSTITUTIONAL
4. Assets in the product
What sub-asset classes will be considered?
5. Holdings consistent with style Assets
Least Which managers/funds will be selected? MIDDLE MARKET
6. Correlation to style or peer group Important
7. Expense ratios/fees
R E TA I L M A R K E T
8. Performance relative to assumed risk
9. Performance relative to a peer group Rigor
Practice M-1.3 Practice M-1.4 Practice SA-1.1 Practice SA-1.2 Practice SA-2.3 Practice SA-2.4 Practice M-2.3 Practice M-2.4
The organization has the capacity Administrative operations are Investments are managed in The roles and responsibilities of all An expected, modeled return to Selected asset classes are consistent There is an effective process for There are effective and appropriate
to service its client base. structured to provide accurate and accordance with applicable laws, involved parties (fiduciaries and meet investment objectives has with the identified risk, return, allocating and managing both external management controls.
timely support services and are trust documents, and written non-fiduciaries) are defined, been identified. and time horizon. internal and external resources
conducted in an independent manner. investment policy statements (IPS). documented, and acknowledged. and vendors.
Practice M-1.5 Practice M-1.6 Practice SA-1.3 Practice SA-1.4 Practice SA-2.5 Practice SA-2.6 Practice M-2.5 Practice M-2.6
Information systems and technology The organization has developed Fiduciaries and parties in interest Service agreements and contracts Selected asset classes are consistent There is an IPS which contains The organization has a defined Remuneration of the company and
are sufficient to support programs to attract, retain, and are not involved in self-dealing. are in writing, and do not contain with implementation and the detail to define, implement, process to control its flow of compensation of key decision-makers
administration, trading, and risk motivate key employees. provisions that conflict with monitoring constraints. and manage a specific funds and asset variation. is aligned with client interests.
management needs. fiduciary standards of care. investment strategy.
Practice M-1.7 Practice SA-1.5 Practice SA-2.7 Practice M-2.7 Practice M-2.8
There is a formal structure supporting
effective compliance.
Assets are within the jurisdiction
of courts, and are protected from
theft and embezzlement.
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ORGANIZE
2
FORMALIZE
The IPS defines appropriately
structured, socially responsible
investment (SRI) strategies
(where applicable).
The organization has responsible
and ethical reporting, marketing,
and sales practices.
There is an effective risk-management
process to evaluate both the
organization’s business and
investment risk.
Practice M-4.1 Practice M-4.2 Practice SA-4.1 Practice SA-3.1 Practice M-3.1 Practice M-3.2
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There is a defined process for the All aspects of the investment system Periodic reports compare investment The investment strategy is The asset management team operates The investment system is defined,
attribution and reporting of costs, are monitored and are consistent performance against appropriate implemented in compliance with in a sustainable, balanced, and focused, and consistently adds value.
performance, and risk. with assigned mandates. index, peer group, and IPS objectives.
MONITOR IMPLEMENT the required level of prudence. cohesive manner.
Practice M-4.3 Practice M-4.4 Practice SA-4.2 Practice SA-4.3 Practice SA-3.2 Practice SA-3.3 Practice M-3.3 Practice M-3.4
Control procedures are in place to There is a process to periodically Periodic reviews are made of Control procedures are in place to Applicable “safe harbor” provisions Investment vehicles are appropriate The investment research process is The portfolio management process
periodically review policies for best review the organization’s qualitative and/or organizational periodically review policies for best are followed (when elected). for the portfolio size. defined, focused, and documented. for each distinct strategy is clearly
execution, “soft dollars,” and effectiveness in meeting its changes of investment execution, “soft dollars,” and defined, focused, and documented.
proxy voting. fiduciary responsibilities. decision-makers. proxy voting.
Practice SA-4.6
LEGEND:
There is a process to periodically Practices in gold that begin with an “SA” define a fiduciary standard of excellence for Investment Stewards and Investment Advisors.
review the organization’s
Practices in blue that begin with an “M” define a fiduciary standard of excellence for Investment Managers.
effectiveness in meeting its
fiduciary responsibilities. “SA” Practices highlighted are best reviewed in conjunction with Investment Managers Practices.
Previously the Chief Knowledge Officer and Director of Training for fi360, he is the primary architect of the AIFA
program and a major contributor to the development of the Fiduciary Excellence concept that is at the heart of our
products and services. He is the author of numerous articles on the subjects of fiduciary responsibility and invest-
ment management, and the author of the monthly Fiduciary Corner column in InvestmentNews magazine.
Rich Lynch is the COO of fi360, which delivers training, tools and resources for investment fiduciaries. As one of
the main instructors for fi360 Training, he is instrumental in providing investment education and training programs
that award the Accredited Investment Fiduciary (AIF) and Accredited Investment Fiduciary Analyst (AIFA) profes-
sional designations. He also provides oversight to fi360 Tools, which has developed sophisticated Web-based tools
and reporting, including the innovative fi360 Fiduciary Score and the Fund Family Fiduciary Rankings for trustees
and investment professionals.
Rich assisted with the development of the industry's fiduciary handbook series, Prudent Practices for Investment
Fiduciaries.
Kristina's is the Director of Legal and Regulatory Affairs at fi360. Her primary role is to research, write, speak and
otherwise represent fi360 on legislative and regulatory developments impacting investment fiduciaries. She also
provides subject matter expertise to the fiduciary professional designation courses and software tools developed by
fi360, acts as legal liaison to outside counsel and serves in a compliance role in the organization.
Prior to joining fi360, Kristina served for over four years as a Special Counsel in the Office of Chief Counsel of the
Division of Trading and Markets at the U.S. Securities and Exchange Commission and specialized in broker-dealer
regulation. Prior to that, she was an associate with Troutman Sanders LLP in its Washington, D.C. office for two
years and specialized in federal energy regulation. Kristina earned her J.D., cum laude, at Georgetown University
Law Center, her MBA at Georgetown University's McDonough School of Business, and her B.S.B.A. in Accounting,
magna cum laude, at Robert Morris University
Andy Frommeyer is the Director of Products and Services with fi360. In this role, he oversees fi360's suite of prod-
ucts and services delivered through the Training, Tools and Resources business lines. He is responsible for the
development of a product from concept through to launch and the management and improvement of existing prod-
ucts.
In his preceding position with fi360, Andy directed the Tools line of business. He helped to develop the fi360
Fiduciary Score™ and the Fund Family Fiduciary Rankings™ as well as other proprietary fi360 innovations that
have become industry standards.
Andy has been with the company since its inception, helping to build it from a start-up operation to one of the most
well known training and technology providers in the industry.
Fi360 • 10 Emerson Lane • Suite 801• Bridgeville , PA 15017 • 412-221-0292 Phone • 866-390-5080 Toll-free phone