The investment manager
must avoid churning and aim to achieve "best execution" according to the Draft Resolution.
As well as using in-house analysts, it is important that a investment manager
can consider the views of other third party investment analysts.
Information resources on the institutional investment industry, including a directory of pension fund consultants and investment managers
The DOL also has concerns about the potential for abuse in index and model-driven fund programs--which the DOL previously had considered as providing investment managers
with limited investment discretion--stemming from the DOL's new understanding of the "subtle" exercise of discretion by investment managers
permitted by such programs.
Say the portfolio doesn't perform well for some reason, certain securities in the portfolio are downgraded or the investment manager
doesn't follow the agreed-upon strategy.
So, should the investment manager
or the plan sponsor do the voting?
We sometimes solicit the advice of the investment manager
in whose portfolio the equity is placed.
We think that fairness has to be part of the formula in how we compensate investment managers
for what they're doing.