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In October of 1998, Alice Freeman, Georgeanne Pallence, and Mark Antonasanti formed FPA Investment Management (FPA). All three of these individuals have enjoyed considerable success in their careers. Freeman is highly regarded for her expertise in the area of security analysis, while Pallence and Antonasanti are well known for their exemplary management of fixed-income and equity portfolios, respectively.

In the initial period after its inception, FPA only accepted high net worth clients, requiring a minimum investment of $5 million. In early 2000, however, FPA made the decision to expand its client base by lowering its minimum investment requirement to $2 million. In the effort to attract new clients and improve the information it provided for its current clients, FPA prepared and distributed performance presentations that reflected the results of its three primary investment styles. That is, FPA presented performance results for an intermediate fixed-income composite, a broad equity composite, and a balanced composite. The following list describes some of the actions that FPA took when preparing its performance presentations.

Action Number

Description

1

All composites included only assets under management and were not linked with simulated or model portfolio performance.

2

Accrual accounting and book values were used to compute fixed-income returns.

3

Trading expenses were deducted prior to calculating returns.

4

Fee schedules were included in the presentations.

5

All actual fee-paying accounts were included in at least one of the three composites.

6

Asset-weighted composite returns were calculated using end-of-period weightings.

7

The performance of the equity portion of the balanced accounts, excluding cash, was combined with the equity composite results.

8

The S&P 500 index was used as the benchmark for all three composite performance presentations.

9

Equal-weighted rates of return that adjust for cash flows were used.

Which of FPA’s actions indicated below is in compliance with the Global Investment Performance Standards (GIPS)?


A. Action 2.
B. Action 1.
C. Action 6.
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