A commentary piece provides investors with updates and the why behind market moves and portfolio decisions. The best commentaries contextualise what’s happened in terms of the fund’s long-term objectives. They increase investor confidence and demonstrate the fund manager’s expertise.
> The commentary below is for a multi-cap equity fund with runaway returns but investors who have a “sustainability first” mindset. This client has requested they be transparent and wants all claims backed by data, but equally, they do not want the success of the fund’s strategy to be missed.
Compliance (UK)
COBS.4.2.1R (fair, clear, not misleading)
COBS.4.2.2R (performance presentation)
COBS.4.5.2R (risk disclosure)
COBS.4.6.7R (forward-looking statements)
COBS.4.6.3R (benchmarking)
SFDR (ESG disclosure)
PRIIPS/COBS/UCITS (fees disclosure, disclaimers)
COBS.4.11R (approved by compliance)
> The commentary below is for an equity fund that has underperformed in the quarter with investors who gave the managers a strict high growth mandate. The asset manager has not given a comprehensive briefing, other than to request a confident tone.
Compliance (US)
SEC Rule 206(4)-1 (investment advisor marketing)
SEC Rule 156, 204(4)-1(e)(1) and (4) (performance)
FINRA Rule 2210 (comms with the public)
SEC Rule 482 (risk disclosure)
Investment Company Act Section 30(e) (fees dis.)
SEC Rule 482(c) (other prominent disclosures)
FINRA Rule 2210(b) (approved by compliance)
