The Revised Fund Manager Code of Conduct and Code of Conduct – What ALL Fund Managers Need to Know


The Revised Fund Manager Code of Conduct (“FMCC”) has become effective on 17 November 2018. This course will give an overview of the major changes to the FMCC and will highlight challenges and key considerations for Fund Managers in order to be compliant with the new requirements.

Detailed Information

Highlights of the course include:

  • Person to whom the FCC applies:
    • Fund managers “responsible for overall operation of a fund” – what does it mean?
    • Private funds
    • Discretionary managed accounts
    • To whom will it NOT apply?
  • Additional disclosure requirements for Funds:
    • Securities lending and REPOs
    • Custodian / safe custody of fund assets
    • Liquidity risk management
    • Disclosure of leverage
    • Fund portfolio valuation
    • Audited financial statements
    • Risk management
    • Side pockets
  • Discretionary Managed accounts
    • Minimum content requirement in Client Agreement – how to modify the Client Agreement – are there difficulties being encountered?
    • Performance review and valuation reports
  • Fund Documentation Update – e.g. PPM, IMA etc. – what happens if not yet done?
  • Fund Distributors – additional disclosures enhancing point-of-sale transparency in the Code of Conduct – what type of disclosures required?
    • Disclosure of monetary and non-monetary benefits
    • Disclosure of transaction related information – independence, etc.
  • Compliance and policies update including conflict of interests, personal account dealing
  • To date – has the new FMCC been operating well?

Registration Conditions

To view our registration conditions click here.