Elements of An Investment Policy Statement For Individual Investors
Elements of An Investment Policy Statement For Individual Investors
AN INVESTMENT
POLICY STATEMENT
FOR INDIVIDUAL
INVESTORS
ELEMENTS OF
AN INVESTMENT
POLICY STATEMENT
FOR INDIVIDUAL
INVESTORS
© 2010 CFA Institute. All rights reserved.
ISBN: 978-0-938367-31-4
May 2010
Contents
INTRODUCTION 1
1. Scope and Purpose 3
1a. Define the context. 3
1b. Define the investor. 3
1c. Define the structure. 4
2.
Governance 6
2a. Specify who is responsible for determining investment policy,
executing investment policy, and monitoring the results of
implementation of the policy. 6
2b. Describe the process for reviewing and updating the IPS. 6
2c. Describe responsibility for engaging and discharging external
advisers. 7
2d. Assign responsibility for determination of asset allocation,
including inputs used and criteria for development of input
assumptions. 7
2e. Assign responsibility for risk management, monitoring, and
reporting. 8
3. Investment, Return, and Risk Objectives 9
3a. Describe the overall investment objective. 9
3b. State the return, distribution, and risk requirements. 9
3c. Define the risk tolerance of the investor. 11
3d. Describe relevant constraints. 12
3e. Describe other considerations relevant to investment strategy. 14
The investment policy statement (IPS) serves as a strategic guide to the planning
and implementation of an investment program. When implemented successfully, the
IPS anticipates issues related to governance of the investment program, planning
for appropriate asset allocation, implementing an investment program with internal
and/or external managers, monitoring the results, risk management, and appropriate
reporting. The IPS also establishes accountability for the various entities that may
work on behalf of an investor. Perhaps most importantly, the IPS serves as a policy
guide that can offer an objective course of action to be followed during periods of
market disruption when emotional or instinctive responses might otherwise motivate
less prudent actions.
The IPS is a highly customized document that is uniquely tailored to the preferences,
attitudes, and situation of each investor. Templates that purport to offer convenience and
ease in development of an IPS almost inevitably sacrifice consideration of factors that are
highly relevant to the investor. The investment professional must thoroughly understand
the investor’s objectives, restrictions, tolerances, and preferences to be able to develop a
truly useful policy guide.
An investor with a current IPS may choose to evaluate that IPS in relation to these
elements, and those embarking on development of a new IPS may choose to consider
focusing on the elements discussed here.
For each element, an example of IPS language is presented that may be relevant to an
individual investor. The examples are entirely fictitious and are provided to suggest how
components might be documented. For an example to reflect appropriate language for a
particular investor would be an improbable coincidence. Rather, the most relevant and
useful language should be developed in consultation between the investment counselor
and the client.
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1. Scope and Purpose
1a. Define the context.
A preamble is often useful to relate information about the investor and/or
the source of wealth as a way of establishing the context in which an invest-
ment program will be implemented.
■■ Example: “The assets of the Leveaux Family Trusts trace back to the estab-
lishment of Leveaux Vintners in 1902 by Claude Leveaux. Over the course
of the next 77 years, three generations of the Leveaux family worked to
build the family business, LVX Industries, to include distilled spirits,
gourmet snack foods, and the LVX chain of cafes in Europe and Canada.
Each business line was grounded in the philosophy of delivering outstand-
ing quality and value to consumers as well as investing in the communities
in which Leveaux did business. In 1979, LVX Industries was purchased by
the British conglomerate FoodCo for the equivalent of US$272 million.
Michelle Leveaux established the Leveaux Foundation with $100 million
of the sale proceeds, and much of the remainder constituted the Leveaux
Family Trusts, which are the subject of this Investment Policy Statement.”
■■ Example: “The trustees of the Wei Family Trust shall designate an invest-
ment adviser who shall have exclusive discretionary authority to invest on
behalf of the Trust consistent with the policies set forth in the Investment
Policy Statement, except that the portfolio established at ZZZ Trust
Company identified as “Wei Trust Discretionary Portfolio 1” shall be
managed exclusively by Mr. Wei Zhang.”
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Scope and Purpose
■■ Example: “The HHH Trust Company will provide custody services and
is responsible for rendering a monthly financial report for the Devereaux
Trust. The HHH Trust Company report shall be considered to be the offi-
cial record for the Trust accounts and shall be the basis for the risk review
to be performed by Judith Jones as adviser to the Trust.”
■■ Example: “By their signatures below, the Xien Trust trustees and LLL
Investment Counsel acknowledge both receipt of this document and
acceptance of its content.”
■■ Example: “As trustee for the Charitable Remainder Trust, Nigel Brown is responsible
for approval of the investment policy and any subsequent changes to it. In their capac-
ity as counselors to the Trust, Tower Capital shall counsel the trustee as to devel-
opment of the Investment Policy, suggest appropriate revisions to the Policy on an
ongoing basis, and monitor and report results achieved through implementation of
the Policy on no less than a monthly basis.”
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Governance
■■ Example: “At least annually, Tower Capital shall review the asset allocation of the
Family Investment Accounts and suggest revisions for final approval by James and
Jennifer Jensen. The asset allocation plan is incorporated as Appendix A to this
Investment Policy Statement. It shall consider the proportions of investments in cash
equivalents, municipal securities, U.S. fixed-income obligations, U.S. large-capital-
ization equities, U.S. small-capitalization equities, and American Depositary Receipts
(ADRs). Tower Capital shall consider expected returns and correlations of returns for
a broad representation of asset classes in the U.S. capital markets and consider antici-
pated changes in the rate of inflation and changes in marginal tax rates.”
■■ Example: “As investment adviser, Tower Capital is responsible for using the state-
ments prepared by CCC Brokerage as a basis for evaluating that the risk profile of
the Jorge Luiz account is consistent with the risk management policies approved and
adopted by Jorge Luiz (see Appendix ZZZ). Tower Capital shall be responsible for
identifying variances in risk positions that exceed tolerable limits as specified in the
risk management policies and shall take prompt corrective action. No less than quar-
terly, Tower Capital shall provide to Jorge Luiz a reporting of the all such variances in
the prior quarter.”
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3. Investment, Return, and Risk
Objectives
3a. Describe the overall investment objective.
The IPS should relate the purpose of the assets being invested to one or more broad
investment objectives.
Identify performance objectives for each asset class eligible for investment.
The IPS should set forth all permissible asset classes in which the portfolio
may be invested. Some investors may benefit from using techniques to risk-
adjust the asset class’s benchmark return and portfolio return for purposes
of comparison. Note that, although some asset classes may not be used at all
times, they should still be identified in the IPS. For each asset class, a brief
description of the class should be provided and a benchmark for performance
should be identified. Within each asset class, subordinate asset classes may be
listed (for example, U.S. large-cap equity may be a subclass of U.S. equity).
■■ Example: “The Family Trust accounts may invest in U.S. equity, U.S.
fixed-income, U.S. money market, and international developed-market
equity securities. The following benchmarks have been selected for com-
parison with each asset class: U.S. equity, Russell 3000 Index; U.S. fixed
income, Barclays Capital U.S. Aggregate Index; U.S. money market,
Lipper U.S. Government Money Market Funds Average; international
developed-market equity securities, MSCI Europe/Australasia/Far East
(EAFE) Index.
Define a policy portfolio to serve as a basis for performance and risk assess-
ments. An asset allocation policy should designate target allocations to each
asset class, with allowable ranges around the targets. Similar targets and ranges
may be specified for subclasses. Overall fund returns, weighted according to
strategic target allocations, may be constructed and compared with overall
actual fund performance. Similarly, some insight as to risk exposures may be
developed from examining deviations from target allocations and violations of
acceptable ranges of deviation.
■■ Example: “An asset allocation plan for the Mendez Charitable Trust is
attached as Exhibit ZZZ, and it shall be subject to periodic review and
change under the sole authority of Jose Carrios as trustee. For each asset
class, a target allocation has been established that reflects the optimized
asset allocation study conducted by Hill Counsel as investment advis-
ers; also established are allowable ranges within which actual allocations
to each asset class may vary. The investment adviser is responsible for
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Investment, Return, and Risk Objectives
adhering to the asset allocation plan and for maintaining actual allocations
to asset classes within the ranges established. Each quarterly report by the
investment manager to the trustee shall confirm actual asset allocations as
of the end of the quarter and shall also confirm that allocations during the
quarter were within allowable ranges.”
For individuals, assessing risk tolerance may be difficult and subjective. Where possible,
the IPS should account for known liabilities to lend some quantitative basis to the risk
tolerance assessment. Individual investors may also require an assessment of their intel-
lectual and emotional tolerance for potential losses associated with risks; for these assess-
ments, interviews or questionnaires can be used. More nuanced approaches may attempt
to define multiple levels of risk associated with avoiding financial catastrophe, maintain-
ing a current standard of living, meeting a specific future financial goal, or developing
significant further wealth. The results of this sort of analysis may suggest boundaries for
tolerance for risk and associated policies (for example, stop-loss or rebalancing policies.)
Such policies may be incorporated in an appendix.
■■ Example: “James and Jennifer Jensen understand that the very nature of risk is uncer-
tainty about the future—specifically, uncertainty as to future investment returns. The
Jensens seek to generate investment returns that are proportional to the risks assumed
in the Family Trust portfolios. Tower Capital, as investment adviser, seeks to imple-
ment an investment strategy that balances the need to build the Family Trust assets as
stated in the objectives identified in the 2009 Financial Plan with the risks associated
with that strategy. Based on the 12 April 2009 Risk Assessment interview with James
and Jennifer Jensen, Tower Capital understands that an absolute loss in any 12-month
period of more than 33 percent is intolerable. At that threshold, therefore, policies and
procedures to minimize risk of further loss should be implemented by Tower Capital.”
■■ Example: “The investment adviser will provide the Family Trust trustees
with a quarterly report that summarizes the performance of each invest-
ment manager, each asset class, and the Family Trust in its entirety.
Although such quarterly reports are essential for monitoring purposes,
evaluation of relative success in achieving investment objectives will be on
a rolling eight-quarter basis.”
■■ Example: “In general, the investment policy will be for the Wen portfo-
lios to invest for appreciation in the taxable individual accounts and invest
for dividend and interest income in the individual retirement accounts. In
addition, the investment adviser shall consider tax-loss harvesting of exist-
ing high-basis holdings as transactionsin similar industries or sectors are
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Investment, Return, and Risk Objectives
Specify any policies related to leverage. The ability to leverage portfolios may
be constrained by policy or a relevant statute. Any such constraint should be
identified in the IPS. In addition, to the extent that different manager portfo-
lios and/or different asset classes have different leverage allowances, account-
ability for monitoring overall leverage should be defined.
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Investment, Return, and Risk Objectives
■■ Example: “In addition to performance reporting, Tower Capital shall report to the
Marcel Family Trust trustees on a quarterly basis the following risk metrics: (1) risk
calculated as the annualized standard deviation of portfolio returns relative to each
portfolio’s specified benchmark and (2) the information ratio for each portfolio based
on annualized returns for the portfolio and benchmark as of the end of each quarter.”
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Risk Management
■■ Example: “On the first business day of each new quarter, the investment adviser
for the Jensen personal accounts shall propose rebalancing transactions to return
the accounts to their target allocations and shall execute these transactions within
two business days of receiving authorization from the Jensen Family Investment
Committee, except that if the principal value of a proposed rebalancing transaction is
less than $50,000, that rebalancing transaction shall be deferred indefinitely.”
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