Violation of Fiduciary Duties and Prohibition Against Use of Non-Public Information

Christine Crumbwell and Dorothy Drummond are two portfolio managers with Neptune Funds. Cristine is managing the personal trust fund of Paul Roker, who created the fund as an income support for his wife and a legacy for his two sons after his wife's death. Dorothy is in charge of a fund created by Katey Koric. Katey had started this fund as a long-term investment but recently decided to shift the asset mix toward municipal and high-income bonds. Her friend pointed out a great investment opportunity in the newly issued, high-yield-high-income Orange County bonds and Katey instructed Dorothy to sell off a large chunk of the stock holdings in the fund and reinvest in the Orange County bonds. Dorothy spoke to Christine about this and they both agreed that the bonds were an excellent buy.

Dorothy carried out Katey's instructions and Christine decided that Paul's portfolio would be better off if she sold some of the small cap stocks and bought the bonds and followed Dorothy's suit.

I. Dorothy has violated Standard IV (B.1) - Fiduciary Duties by not discussing the issues further with Katey.

II. Christine has violated Standard IV (B.1) - Fiduciary Duties by tilting the portfolio mix toward high-income instruments.

III. Katey has violated Standard V (A) - Prohibition Against Use Of Non-Public Information.