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Digital Bank of Singapore (DBS) is a private bank that provides investment advisory and wealth management solutions

Digital Bank of Singapore (DBS) is a private bank that provides investment advisory and wealth management solutions


Digital Bank of Singapore (DBS) is a private bank that provides investment advisory and wealth management solutions. It is headquartered in Singapore but has offices in Australia and Hong Kong as well.

Edwin Ho was hired by DBS after graduating summa cum laude in finance from a reputable local university. On his first day at the bank, Edwin meets with his supervisor, Jonathan Tan, CFA.

The following is an excerpt from their meeting:  Jonathan: “I see that you have been an intern with us before. So must be familiar with DBS’ processes. I also notice that you have passed Level I of the CFA examination. That’s great because our Code of Conduct is based on the CFA Institute Code of Ethics and Standards of Professional Conduct, so you should be well-versed in its content.

After this meeting, I will email you a copy of the DBS Employee Handbook, which contains our Code of Conduct and Compliance Manual. You are expected to understand and adhere to all of the handbook’s policies and guidelines. I have to rush for a meeting, but you can peruse the handbook on your own.

However, you must complete and sign this acknowledgement that you have read and agree to abide by the handbook’s policies and guidelines by the end of the week. Please ask me or the folks in the compliance department should you have questions.”

Edwin: “Ok, great. I am already hitting the ground running as I have meetings with two potential clients lined up for later today—Mr Andrew Matthews from Australia and Madam Neo Loh Ping from Malaysia. See you around!”

Edwin then heads for his meeting with Andrew, who is interested in opening a new account with DBS. As part of the onboarding process, Edwin learns that Andrew Matthews and his wife Jane are both 50 years old, have no children, and live in Sydney, Australia.

Andrew’s father recently died and left his entire estate to Andrew, who expects to receive his after-tax inheritance of AUD 9 million in one year. The Matthews both plan to retire at that time and would like help to establish an investment plan.

The couple currently owns a home valued at AUD 3.9 million, do not have a portfolio of investable assets, and do not consider their home as part of their investable assets. In one year, their home mortgage balance will be AUD 3.7 million and other outstanding debt will be AUD 160,000. They will pay off their mortgage and other debts once the inheritance is received.

Currently, Andrew and Jane have a combined after-tax salary of AUD 500,000, incurred AUD 263,000 over the past year in living expenses, and make annual amortised mortgage payments of AUD 237,000. Matthew’s company will pay him an after-tax pension of AUD 51,000 starting one year after he retires, with the payments increasing by the rate of inflation, which is expected to be 3% annually. His employer will continue to pay all of the Matthews’ medical costs until Andrew or Jane dies, whichever comes later.

The Matthews expect their living expenses to also grow at the rate of inflation and ask you to use the average life expectancy in Australia of 82 years for planning. The Matthews consider their investment base to be large given the inheritance, want their portfolio to be invested conservatively, and want to maintain the real value of their investable assets over time.

They plan to leave any assets left in their estate to charity. Edwin notes that the effective tax rate is 20% and the risk-free rate is 2.5%. After having taken down all of this information, Edwin then makes his way for his meeting with Madam Neo, whom he is meeting for the first time.  Madam Neo is a 65-year-old homemaker who is widowed. Ever since her husband passed on, Madam Neo has put most of her life savings in fixed deposits. Occasionally, she speculates in stocks when she receives tips from her neighbours. However, she now wants to invest more conservatively so that she can pay for her grandchildren’s college education. The following is a translated excerpt from the Mandarin conversation between Madam Neo and Edwin:  Madam Neo: “Wow, I wasn’t expecting you to be so young. Do you have much experience managing portfolios?”

Edwin: “Don’t worry. I graduated top of my class and passed the CFA level I exam, which is one of the world’s most rigorous professional qualifying exams for investment. So, I’m more qualified than most young people my age in this job.”

Madam Neo: “That’s reassuring to know. I heard from my friends that your bank offers this oil-linked note that pays 10% interest a year? That’s much higher than one I’m currently getting from my fixed deposits. My energy stocks have been doing so poorly too. I need to invest in something new.”
Edwin: “You betcha. It’s our hottest product—I highly recommend it.”
Edwin offers Madam Neo a brochure on the structured note. However, the brochure is in English, a language in which Madam Neo is not proficient.

So Edwin provides an oral summary of the product in Mandarin, explaining to Madam Neo that the product’s return is linked to the performance of a basket of oil-futures indexes. Although Edwin does not translate the full product terms and conditions, which is in fine print, he does caution Madam Neo that the 10% annual interest is not guaranteed.

Also, while the principal is fully protected if the note is held to maturity, Edwin cautions that there will be a penalty for early redemption of the note, which will mature in 7 years. He also tells Madam Neo that, since the product was launched three years ago, the requirements for interest payment have been met every year.

Madam Neo is neither sure what oil futures are nor how they work, but she decides to invest USD 100,000 into the note anyway. Edwin promptly executes the transaction at Madam Neo’s request.
A year later, Madam Neo is shocked when she does not receive any payments from the structured note. She learns from her friends that a pandemic has curtailed all travel and caused oil prices to fall off a cliff, and prices are likely to stay depressed with no end in sight.

Panicked, Madam Neo calls Edwin on his mobile phone because she could not reach him on his office phone and instructs him to immediately redeem the structured note and place the redemption proceeds in a fixed deposit instead.

Edwin suggests that Madam Neo consider the full costs before proceeding, but Madam Neo says she is already late for a manicure appointment and tells Edwin to act on it immediately. Even though Edwin was not able to record the conversation, he redeemed the note for her because of the urgency of the request.

Several weeks later, Madam Neo learns that the redemption proceeds is only USD 60,000. She calls Edwin again, demanding an explanation. Edwin reminds her that he had warned her about the early redemption penalty when Madam Neo was considering the product.

Madam Neo claims that she is aware of the penalty but not how significant the penalty would be. She also argues that she was under the impression that the product is low-risk because Edwin told her there had been consistent prior payouts previously.

Outraged, Madam Neo files a complaint against Edwin. The regulator opens an investigation and considers Madam Neos’s case a strong one, as she is a “vulnerable client” in the eyes of the law. Vulnerable clients are individuals who meet two of the following criteria: aged 62 years or older; not proficient in English; have below high-school certification or equivalent academic qualifications.

Edwin tells his supervisor Jonathan that he is not aware of the “vulnerable client” condition as this is not part of the CFA Institute Code of Ethics and Standards of Professional Conduct. Jonathan tells Edwin that the “vulnerable client” condition is specified in the DBS employee handbook and that by signing and submitting the employee acknowledgement page during his first week at DBS, Edwin had acknowledged his understanding of the “vulnerable client” condition.

Question 1
As part of drafting an investment policy statement for the Matthews:
(a) Estimate their return objective.
(b) Assess their risk tolerance.
(c) Discuss their investment constraints.

Question 2
Specify at most five (5) violations of the CFA Institute Code of Ethics and Standards of Professional Conduct. State clearly who violated the Code and Standards, which specific Standard or part of the Standard has been violated, and present evidence from the case to support your answer. Each non-violation that has been incorrectly identified as a violation will be penalised, as will any violations in excess of five, including correct ones.

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