Propose practices and procedures that head off breaches of the Code and Standards under Standard V, Investment Analysis, Recommendations, and Actions

Firms can make a reasonable basis routine: a written due diligence checklist for sub-advisers, data vendors and third-party research, repeated periodically; independent validation of models, with back-tests and stress tests documented before deployment; and investment committee minutes recording why each strategy was adopted. For communication, standard client documents should set out fees and all costs, the process, and its main risks, and a change-management procedure should trigger prompt notice to clients when the process, key staff or risk profile changes. Projections should be labelled as opinion with their assumptions shown. A records policy should follow local rules, or keep files for at least seven years where none exist, stored centrally because records are the firm's property rather than the manager's.