| Description |
Anderb, a portfolio manager for XYZ Investment Management Company—a
registered investment organization that advises investment firms and private
accounts—was promoted to that position three years ago. Bates , her supervisor,
is responsible for reviewing Anderb’s portfolio account transactions and her
required monthly reports of personal stock transactions. Anderb has been using
Jonelli, a broker, almost exclusively for brokerage transactions for the portfolio
account. For securities in which Jonelli’s firm makes a market, Jonelli has been
giving Anderb lower prices for personal purchases and higher prices for personal
sales than Jonelli gives to Anderb’s portfolio accounts and other investors. Anderb has been filing monthly reports with Bates only for those months in which
she has no personal transactions , which is about every fourth month. Which of
the following is most likely to be a violation of the Code and Standards? |