FRM Part II · FRM Exam Part II · Performing Due Diligence on Specific Managers and Funds
An investor reviews a fund with USD 500 million reported assets. The fund's administrator confirms NAV only from manager-supplied prices. Of the portfolio, 60% is in Level 3 illiquid positions valued internally by the portfolio manager, who earns a 20% performance fee. Which conclusion is most appropriate?
Valuation risk is high. USD 300 million, 60% of assets, is valued internally by the manager who earns a 20% performance fee, creating a conflict of interest. The administrator only uses manager prices, so there is no independent check; an independent valuation policy and review are required.
- AValuation risk is low because an administrator is engaged
- BValuation risk is high because the manager controls the pricing of USD 300 million of assets and benefits from higher marks, so independent valuation policy and review are neededCorrect
- CValuation risk is low because performance fees align interests
- DValuation risk is only relevant if the fund suffers redemptions
Explanation
60% of USD 500 million is USD 300 million valued by the party paid on performance, a clear conflict. The administrator merely relays manager prices and provides no independent check. Performance fees give an incentive to inflate marks, so independent valuation committee procedures are needed.
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