Felix Asterix is a shrewd industry analyst working for Obelix, Inc., a brokerage firm of some repute. Asterix had invested about $50,000 in a few stocks trading on the Australian exchange a year ago. Obelix itself is not active outside the US and Asterix's transactions do not represent any violations of the company policies.
One of the Australian firms whose shares Asterix holds recently applied for a dual listing on the NYSE and will begin trading in the US in a month. Asterix has advised in his recent research reports that investors would be well-off investing in this dual-listed stock. He does not reveal his holdings in the Australian stock.
Felix has:
I. not violated the AIMR standard since his transactions took place long before the dual listing and he is not obligated to reveal his personal holdings.
II. violated Standard III (C) - Disclosure of Conflicts to Employer.
III. violated Standard IV (A.3) - Independence and Objectivity.
IV. violated Standard IV (B.7) - Disclosure of Conflicts to Clients and Prospects.
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A. B. C. D.D
This is a classic case of potential conflict and appearance of conflict of interests. Indeed, this kind of situation is so common that it is covered by multiple AIMR standards of ethics. Asterix, as an investment advisor and analyst, should be extremely careful about any potential conflicts of interest that might be perceived as affecting the objectivity of his judgment. Clearly, his substantial Australian holdings, while not in violation of company policies when purchased, are a source of bias now that the stock is trading in the US. Felix must discuss the situation with the Compliance Department at Obelix, Inc. and if he receives the permission to continue holding the stock, should reveal his vested interests to all his potential clients. This ensures that there is no perception of unfair bias and lack of objectivity in his investment recommendations.