Q: 6
Martha Gillis, CFA, trades currencies for Trent, LLC. Trent is one of the largest investment firms in the
world, and its foreign currency department trades more currency on a daily basis than any other
firm. Gillis specializes in currencies of emerging nations.
Gillis received an invitation from the new Finance Minister of Binaria, one of the emerging nations
included in Gillis's portfolio. The minister has proposed a number of fiscal reforms that he hopes will
help support Binaria's weakening currency. He is asking currency specialists from several of the
largest foreign exchange banks to visit Binaria for a conference on the planned reforms. Because of
its remote location, Binaria will pay all travel expenses of the attendees, as well as lodging in
government-owned facilities in the capital city. As a further inducement, attendees will also receive
small bags of uncut emeralds (as emeralds are a principal export of Binaria), with an estimated
market value of $500.
Gillis has approximately 25 clients that she deals with regularly, most of whom are large financial
institutions interested in trading currencies. One of the services Gillis provides to these clients is a
weekly summary of important trends in the emerging market currencies she follows. Gillis talks to
local government officials and reads research reports prepared by local analysts, which are paid for
by Trent. These inputs, along with Gillis's interpretation, form the basis of most of Gillis's weekly
reports.
Gillis decided to attend the conference in Binaria. In anticipation of a favorable reception for the
proposed reforms, Gillis purchased a long Binaria currency position in her personal account before
leaving on the trip. After hearing the finance minister's proposals in person, however, she decides
that the reforms are poorly timed and likely to cause the currency to depreciate. She issues a
negative recommendation upon her return. Before issuing the recommendation, she liquidates the
long position in her personal account but does not take a short position.
Gillis's supervisor, Steve Howlett, CFA, has been reviewing Gillis's personal trading. Howlett has not
seen any details of the Binaria currency trade but has found two other instances in the past year
where he believes Gillis has violated Trent's written policies regarding trading in personal accounts.
One of the currency trading strategies employed by Trent is based on interest rate parity. Trent
monitors spot exchange rates, forward rates, and short-term government interest rates. On the rare
occasions when the forward rates do not accurately reflect the interest differential between two
countries, Trent places trades to take advantage of the riskless arbitrage opportunity. Because Trent
is such a large player in the exchange markets, its transactions costs are very low, and Trent is often
able to take advantage of mispricings that are too small for others to capitalize on. In describing
these trading opportunities to clients, Trent suggests that "clients willing to participate in this type of
arbitrage strategy are guaranteed riskless profits until the market pricing returns to equilibrium."
Based on the information given, and according to CFA Institute Standards, which of the following
statements best describes Trent's compliance procedures relating to personal trading in foreign
currencies? The compliance procedures:
Options
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