Covid-19 (Coronavirus): How We See It
A UNIQUE CHALLENGE
Many of our clients and friends have reached out to DMS in the past few days to ask us about “best practice” for Investment Managers in dealing with disclosure, reporting and human resource matters in relation to Covid-19.
Given the unprecedented and fast-moving nature of this new risk, we cannot say for sure if best practices have yet to be determined. We have, however, put together some observations on the response of some within the industry. These are based on conversations and communications with a selection of managers (located predominantly in the North-East U.S., across a range of strategies and asset and personnel size) over the past few days. It is important to keep in mind that risk varies significantly by location.
A COMMON DENOMINATOR WAS EVIDENT – EMPLOYEE SAFETY IS PARAMOUNT
- 100% of managers have tested their Business Continuity Plan (BCP) and believe they will have to use it at some point during the next quarter.
- 100% of managers have spoken to their employees about social distancing and have put policies in place, for example, no hand shaking.
- 100% of managers have requested that non-essential travel be suspended.
- Over 90% have implemented an optional work from home policy for all or non-essential employees for an unspecified time. They indicate that they will review the policy every two weeks. The only exceptions to this have been smaller managers with less than five employees.
- Less than 5% have made work from home mandatory at this stage.
- Approximately 80% have indicated to employees that they would be willing to finance non-public transportation should those employees choose to travel into work. Again, this statistic correlates to asset size. Most managers >$500M and all above $1Bn have implemented this policy.
- 20% of managers have cancelled all face-to-face meetings (in their office or externally).
EFFECTS ON INVESTOR DISCLOSURE AND REPORTING
Approximately 72% have indicated that they have, or will have, sent a Covid-19 specific note to investors via email or accompanying the periodic performance estimate. The note includes the following:
- How Covid-19 has affected or may affect their portfolio in the future and including an explanation in the event that it has not been affected.
- Current performance.
- A high-level summary of their BCP and confirmation that one exists.
- Details of their human resource policy in reaction to the circumstances (including work from home options, for example).
It is also interesting to note that 75% of managers who do not currently offer weekly performance estimates have now committed to doing so for an unspecified time frame.
Some law firms have suggested that funds that believe that the risk section of their offering document neglects to sufficiently include pandemics like Covid-19 may want to consider updating these or highlighting this risk as part of their upcoming Form ADV filing. Very few managers in our survey indicated they would need to or would be likely to do this.
We plan to send further updates over the coming days should conditions and peer practices change significantly. Please get in contact with us if you have any comments or observations on the current situation. We hope that you have found this update helpful.
DMS’ RESPONSE TO COVID-19 (CORONAVIRUS)
DMS continues to stay up to date with the latest Covid-19 (Coronavirus) developments and is following the guidelines provided by the World Health Organisation (WHO). During this time, the health and wellbeing of our staff, their families and our clients is our priority.