2022 LI Ethics

Last Revised: 06/09/2021
MarkMeldrum.com
Level I - Ethical and Professional Standards

Readings Page
Ethics and Trust in the Investment Profession 2
Code of Ethics and Standards of Professional Conduct 9
Guidance for Standards I-VII 15
Introduction to the Global Investment Performance Standards

66
(GIPS®)
Ethics Applications 70
Reviews 71
This document should be used in conjunction with the corresponding readings in the 2022 Level I CFA® Program curriculum.
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Ethics and Trust in the Investment Profession
a. explain ethics;
b. describe the role of a code of ethics in defining a profession;
c. describe professions and how they establish trust;
d. describe the need for high ethical standards in investment management;
e. explain professionalism in investment management;
f. identify challenges to ethical behavior;
g. compare between ethical and legal standards;
h. describe a framework for ethical decision making.

Ethics
Page 1
encompasses a set of moral principles and LOS a
rules of conduct that provide guidance for our behaviors - explain
- moral/ethical principles - beliefs regarding what is good,

acceptable or obligatory behavior and what is
bad, unacceptable or forbidden behavior
- may be individual as well as shared beliefs regarding

standards of behavior expected or required
- ethical conduct - behavior that follows moral principles

- balances self-interest with direct/indirect
consequences of behavior on others
e.g./ honesty, fairness or justice, diligence, respect for the rights

of others
Page 2
code of ethics/ a codified guide that LOS a
communicates an organization’s/profession’s - explain
expectations regarding member behavior

Standards of conduct - established benchmarks that clarify
or enhance a group’s code of ethics
(minimally acceptable behavior)
Violations/ - can harm the community’s reputation both
externally & internally
- to protect innocent members (limit potential harm)

violations are investigated - repair any damage
- discipline the violator
- revoke membership
Ethics & Professionalism

Page 3
- a profession is/ based on specialized knowledge LOS b
and skills - describe
based on service to others
practiced by members who share and agree
to adhere to a common code of ethics
- in any given profession, a code of ethics communicates the

shared principles and expected behaviors of its members
- provides guidance to members
members of profession
- generates confidence among
clients/general public
- Standards of conduct enhance and
clarify the code of ethics - rules-based - more narrowly defined
principles-based - usually applied to specifics
(apply to all members at all times) (individuals, circumstances)
Professionalism in Investment Mgmt.

Page 4
Profession an occupational group that has specific LOS c
education, expert knowledge and a framework - describe
of practice and behavior that underpins community trust,
respect and recognition
Driving forces
Individuals - see an
Governments advantage in
& Regulators Profession working as a
professional
- encourage the formation
of an ethical relationship Clients - a desire to work
between professionals and with professionals
society at large
clients
Primary goal establish trust among
society
benevolence competence
Page 5
1/ Professions normalize practitioner behavior - codes and LOS c
standards of behavior - describe
2/ Professions provide a service to society - support economic activity

by encouraging trust in the industries they serve
- professionals advocate for higher educational and ethical
standards in the industry
3/ Professions are client focused - place the integrity of the

profession and the interests of the clients above their
own personal interests
4/ Professions have high entry standards - thus membership is a

signal to the market
5/ Profession possesses a body of expert knowledge
6/ Professions encourage and facilitate continuing education

- continuing professional development
Page 6
7/ Professions monitor professional conduct - monitoring LOS c
& imposition of sanctions on members - describe
8/ Professions are collegial
9/ Professions are recognized overseeing bodies - not-for-profit

organizations emphasizing excellence, integrity and public service
10/ Professions encourage the engagement of members - through

volunteer efforts to advance the profession and engage with peers
LOS e
investment management is a relatively young profession - explain
public understanding, recognition by employers and
regulators is still developing
- investment management profession meets most, but currently

not all of the expectations of a profession
CFA Institute as an Investment Management Professional Body

Page 7
Expectations: honesty, integrity, altruism, continuous LOS e
improvement, excellence, loyalty, and respect for - describe
colleagues, employers and clients
- uphold the reputation of their profession

- be responsible, accountable, reliable
- duty to be honest and open in dealings
- acknowledge mistakes promptly, learn from them, correct them
- ethical dilemmas should not avoid responsibility for

taking action
Investment Industry & Ethics

Page 8
- enhances allocational efficiency
LOS d
- investors and society benefit when capital - describe
flows to borrowers that can create the most value
- capital flows more efficiently when financial market

participants are confident that all parties will behave
ethically (builds & fosters trust)
- investors/borrowers more willing to take risks
- higher trust lowers the cost of capital for borrowers
- financial markets/investment industry are built on trust

- investors entrust their assets to financial firms
- nature of product/service
- indirect & intangible
- reputation effect - clients are attracted to firms with

trustworthy reputations
Challenges to Ethical Conduct

Page 9
1. Overweighting our own ethical disposition LOS f
- it is not so much what we believe - identify
about ourselves, it is what others believe about us
- I am honest vs. do others see me as honest?
2. Underweighting the situational influences
external factors that shape our

thinking, decision making & behavior
- money & prestige
- loyalty - organization, peers
3. Limitations to organizational compliance

- creates rule followers – check the boxes
- insufficient for ensuring ethical decision

making
Ethical vs. Legal Standards

Page 10
LOS g
- distinguish
goes beyond what is legally
Legal both Ethical required
(encompasses correct behavior)
laws & regulations - vary across countries/jurisdictions
- usually insufficient to ensure

ethical behavior
Ethical Decision-Making Frameworks

Page 11
- frameworks are designed to facilitate LOS h
the decision-making process - describe
- apply
- see a problem from multiple perspectives
- identify issues that may not have been
considered otherwise
- increase the ability (and motivation) to act ethically
e.g./ Identify - relevant facts, stakeholders and duties owed,

ethical principles, conflicts of interest
Consider - situational influences, additional guidance,

alternative actions
Decide and Act
Reflect - was the outcome as anticipated? Why/Why not?

Code of Ethics and Standards of Professional Conduct
a. describe the structure of the CFA Institute Professional Conduct Program

and the process for the enforcement of the Code and Standards;
b. identify the six components of the Code of Ethics and the seven Standards of
Professional Conduct;
c. explain the ethical responsibilities required by the Code and Standards,

including the sub-sections of each Standard.
Professional Conduct Program

LOS a
- all members + candidates (M/C) are required - describe
to comply with the Code & Standards C/S
CFA
Board of Governors volunteers
oversight (CFA charterholders)
Professional Conduct Disciplinary Review

Program Committee
(PCP) (DRC)
responsible for the enforcement of

the ‘Code’ and ‘Standards’
LOS a
Conduct inquires may originate from: - describe
1) M/C self-disclosure on the annual
Professional Conduct Statement
disclose: civil litigation
criminal investigations
subject of a written
2) written complaints complaint
received by the Professional Conduct staff
3) CFA staff through media, regulatory notices
4) exam proctors
5) post-exam behavior (online disclosure of

confidential exam material)
LOS a
- inquiry initiated/
- describe
- request for a written explanation from the M/C
- interviews with M/C, complaining party, other

relevant 3rd parties
- collecting documents/records
- may result in/

· no action
· issue a cautionary letter
· continue to disciplinary action
· if the M/C rejects the result, goes to the DRC
LOS a
Sanctions/ · public censure - describe
· suspension of membership and use of the
CFA designation
· revocation of the CFA charter
· candidates suspension/prohibition from
further participation
Adoption of the Code and Standards/

- apply to M/C
- firms are encouraged to adopt (also
nonmembers)
“So-and-so claims compliance with the CFA Institute
Code of Ethics and Standards of Professional Conduct.
This claim has not been verified by CFA Institute”
LOS a
Code & Standards individual investment
- describe
professionals
Asset Manager Code of Professional Conduct drafted

especially for firms
Why Ethics Matters/
a set of moral principles or rules of conduct
that provide guidance for our behavior when it
affects others
Direct/Indirect
Self Interest vs. Consequences to
Others
members
- protects integrity of firms
profession
markets
Six + Seven
LOS b
Code of Ethics/ - state
act with integrity, competence, diligence, and
respect and in an ethical manner with:
the public
clients (current & prospective)
employers
employees
colleagues
Place the integrity of the investment
profession and the interest of clients
above their own personal interests
LOS b
Use reasonable care and exercise

independent professional judgement when
conducting investment analysis, making
investment recommendations, taking investment
actions
Practice, and encourage others to practice,

in a professional and ethical manner that
will reflect credit on themselves and the
profession
LOS b
Promote the integrity and viability of the

global capital markets for the ultimate
benefit of society
Maintain and improve professional

competence and strive to maintain and
improve the competence of other
investment professionals
ongoing education
LOS b, c
Standards of Professional Conduct/ - state
1. Professionalism - explain
A. knowledge of the Law

B. Independence and Objectivity
C. Misrepresentation
D. Misconduct
2. Integrity of Capital Markets

A. Material Nonpublic Information
B. Market Manipulation
LOS b
Standards of Professional Conduct/ - state
3. Duties to Clients
A. Loyalty, Prudence and Care
B. Fair Dealing
C. Suitability
D. Performance Presentation
E. Preservation of Confidentiality
4. Duties to Employers
A. Loyalty
B. Additional Compensation Arrangements
C. Responsibilities of Supervisors
LOS b
Standards of Professional Conduct/
- state
5. Investment Analysis, Recommendations & Actions
A. Diligence and Reasonable Basis
B. Communication with Clients and Prospective
C. Record Retention Clients
6. Conflicts of Interest
A. Disclosure of Conflicts
B. Priority of Transactions
C. Referral Fees
7. Responsibilities as a CFA M/C

A. Conduct as M/C in the CFA program
B. Reference to CFA Institute/Designation/Program
Guidance for Standards I-VII
a. demonstrate the application of the Code of Ethics and Standards of

Professional Conduct to situations involving issues of professional integrity;
b. identify conduct that conforms to the Code and Standards and conduct that
violates the Code and Standards;
c. recommend practices and procedures designed to prevent violations of the

Code of Ethics and Standards of Professional Conduct.
Professionalism
A. Knowledge of the Law/

- comply with all applicable laws, rules, and
regulations of any government, regulatory
organization, licensing agency or professional
association governing their professional activities
- in the event of conflict, comply with the

more strict law or regulation
- must not knowingly participate or assist in and

must dissociate from any violation of such
laws, rules or regulations
A. Knowledge of the Law/ Guidance
M/C must understand the applicable

laws/regulations of the countries/jurisdictions
where they engage civil
M/C must comply with laws/regulations that

directly govern their profession/activities
M/C should know their firm’s policies/procedures

for assessing compliance guidance
stay up to date regulations change


C/S vs. Applicable Laws/
- when they require different conduct,
must follow the stricter
e.g./ NS – no laws LS – less strict MS – more strict
1) live in NS, do business in LS C/S
2) live in NS, do business in MS MS regardless

of situation,
3) live in LS, do business in NS C/S
choose C/S
4) live in MS, do business in NS or LS MS unless law
5) live in LS, do business in MS MS is MS

Participation in or Association with Violations
by Others/
M/C are responsible for violations they
knowingly participate in or assist
if M/C believes (reasonable grounds) violations
are or will occur, must dissociate (or separate)
from the activity (may involve resignation)
report to employer/compliance
step away
report to CFA

Investment Products & Applicable Laws/
M/C involved in creation of products/services
should:
understand laws/regs. of country of origination
& of expected sale and ensure their
distributors also abide by applicable laws/regs.
Compliance – M/C
1. Stay informed
2. Review procedures (compliance)
3. Maintain current files (laws, statutes, regulations)

Compliance
- seek the advice of legal/compliance
- dissociate
Firms/
develop/adopt a code of ethics
provide information on applicable laws
establish procedures for reporting violations
M/C must use reasonable care and

judgment to achieve and maintain independence
and objectivity in their professional activities
M/C must not offer, solicit, or accept

any gift, benefit, compensation, or consideration
that reasonably could be expected to compromise
their own or another’s independence and
objectivity
B. Independence and Objectivity/Guidance
M/C should avoid real/perceived situations

that could cause a loss of independence or
objectivity in recommending investments or taking
investment action (extends to social situations)
modest gifts/entertainment acceptable
if from a client, should disclose to employer

- considered supplementary compensation
M/C personally responsible for maintaining

independence/objectivity (research, recomm., actions)
- true opinions free from bias

Investment Banking Relationships
pressure to issue favourable research
reports on current/prospective inv. banking clients
analyst should not be coerced/enticed

into issuing research that does not reflect
their true opinions
‘firewalls’ must be managed

(between inv. banking & research)
- separate reporting structures
- compensation that rewards
objectivity and accuracy

Public Companies
pressure to issue favourable reports by
the companies they follow
negative views may make it difficult to
get access (mgmt., conference calls)
Buy-side clients
port. mgrs. may not want negative
opinions released (or at least a warning)
port. mgrs. (may also be CFA holders) must

not interfere with research objectivity
(directly/indirectly)

Fund Mgr. & Custodial Relationships
M/C who are responsible for selecting PMs
& custodians must appear independent
Credit Rating Agency Opinions

M/C at rating agencies must report
without undue influence from the client co.
M/C should understand this conflict if

consumers of research
Issuer-paid research M/C must disclose potential

conflicts of interest including nature of the
compensation (flat fee or options/warrants)

Travel Funding – introduces conflict, also must
consider the effect of context on
objectivity
- analysts should use commercial travel
at their/firm expense (avoid the appearance)
- if available
Performance Measurement & Attribution

for those working within a firm’s
investment performance measurement department
reporting on company run fund performance

Influence during the Manager Selection/Procurement
Process
M/C must not solicit gifts, favours,
donations from the target hires (if in a
position to do so)
should also refuse gifts
if on the other end (being considered) must not

use gifts or favours
Don’t be influenced & don’t influence

(both covered by Standard 1B)

Recommended Procedures for Compliance/
Protect the integrity of opinions
- every research report reflects the
unbiased opinion of the writer
Create a restricted list

- no coverage if adverse opinion is
not welcomed
Restrict special cost arrangement

- no payment/reimbursement by any
corporate issuer
Limit gifts – token items only

- business-related entertainment

Recommended Procedures for Compliance/
Restrict Investments
- such as in IPOs/private placements
Review procedures – supervisory/review

procedures related to personal investments
Independence Policy – written policy about

the independence & objectivity of research
- research analysts not supervised by

potential influencing department
C. Misrepresentation
M/C must not knowingly make misrepresentations

relating to investment analysis, recommendations,
actions or other professional activities
Guidance/
any written untrue statement or omission of
fact
any false/misleading statement
(oral, written, electronic)
M/C should not guarantee investment
performance (unless part of the product)
C. Misrepresentation/ Guidance/
Impact on Investment Practice
M/C must not misrepresent any aspect of

their practice, credentials, qualifications,
performance record
exercise care/diligence when using

3 rd
party information
disclose intended use of external

managers and must not claim their performance
as their own
Performance Reporting
M/C should not misrep. the success of their

performance record
(using noncomparable benchmarks)
should use appropriate 1C. does not

actually require
benchmarks for performance
a benchmark to
and fee calculation
be provided
should provide accurate and
reliable security pricing to clients
Omissions
model input
- any data point
composite development
Social Media
M/C same information as allowed to

distribute to clients (current/potential)
all communication through SM adhere to

the C/S
anonymity is no release from obligations

Plagiarism
practice of copying, using in substantially
the same form, materials prepared by others
without acknowledging the source
- claiming research as your own
- using excerpts verbatim (or slight
changes)
Plagiarism
- citing quotations as from ‘leading analyst’
without specific reference
- presenting statistical estimates/forecasts
prepared by others with citation but without
statements of limitations that may have been
used
- using charts/graphs without
stating source
- copying proprietary computerized
spreadsheets/algorithms without cooperation or
authorization of creators
Plagiarism
- ok to distribute 3rd party reports, even
to precis those reports
- extends to oral communication, use of
audio/video media, electronic media
Work completed for Employer

- may use previous internal research
(property of the firm)
- may not simply reissue a previously
released report solely under their own name
C. Misrepresentation/
Recommended Procedures for Compliance
Factual presentations
- firms can provide guidance for
written/oral communication
- designating who can speak on behalf
of the firm
Qualification Summary – provided as part of
the presentation
Verify outside information
Maintain webpages – monitor materials
posted
C. Misrepresentation/
Plagiarism Policy
maintain copies of source material
(every reference)
attribute quotations
(projections, tables, statistics)
attribute summaries
(paraphrases or summaries)
D. Misconduct
M/C must not engage in any professional
conduct involving dishonesty, fraud, or deceit or
commit any act that reflects adversely on their
professional reputation, integrity, or competence
Guidance different from 1A. – legal/regulatory

1D – all conduct that reflects poorly on
the integrity/reputation of the M/C
conduct that damages trustworthiness or
competence
- abusing alcohol/drugs during business hours,
personal bankruptcy brought about by fraudulent/
deceitful business conduct
D. Misconduct
Guidance – even the absence of appropriate
conduct or the lack of sufficient effort
(relying on someone else)

Code of Ethics
- develop/adopt, to which every
employee must subscribe
List of Violations
- plus associated disciplinary actions
Employee references
- check those given, plus others
Integrity of Capital Markets

M/C who possesses material nonpublic
information that could affect the value of an
investment must not act or cause others to act
on the information
Material if its disclosure would likely have an impact

on the price of the security
if reasonable investors would want to know
the information before making an investment decision
i.e./ earnings, M&A, change in assets, innovations, discoveries,

customer/supplier changes, mgmt. changes, changes in
auditor opinion, defaults, bankruptcy, legal disputes, large
block orders
test – consider the source and likely effect

less reliable, less likely more
ambiguous, less
- if the price effect is unclear, may likely
not be considered material
Nonpublic information is nonpublic until it has been

made available to the public
- selectively disclosed by a corporation to a

small group of investors or analysts
its ok to get it, but not

to act on it

Mosaic Theory analysis of public may lead to
information a conclusion
save and
+ that may
document all
analysis of non material be material
research
nonpublic info. nonpublic
Social Media
M/C should verify that info. from here is
publicly available from another source
if you distribute info. with SM, make sure
any regulatory filings have been made

Using Industry Experts
M/C may pay for expert insight, but
not for confidential information the expert
may be privy to
Investment Research Reports

analyst effect report may move
markets
since analyst is not a company
insider and did not use material, nonpublic
info., report does not have to be made public
before sharing

achieve public dissemination
- encourage the issuer to make the
information public
Adopt compliance procedures
- review of employee and proprietary
trading
Adopt disclosure procedures
- designed to ensure that information
is disseminated equitably

Issue press releases
‘Firewall’ elements – within firms
information barrier
- interdepartmental communication
- review of employee trading
(watch, restricted, rumor lists)
Appropriate interdepartmental communication
- formalized
Physical separation of departments
- and files

Prevention of personnel overlap
- inv. banking vs. corp. fin.
- sales vs. research
Reporting system – have an information
barrier in place
Personal trading limitations
- by employees, reports of trading
activity and for those made for the
benefit of family members
- use of a restricted list

Record Maintenance
- written records of communications
among departments
Proprietary trading procedures
- restrictions will depend on the
nature of the trading
Communication to all employees
- compliance policies and guidelines
- proper training boring
M/C must not engage in practices that
distort prices or artificially inflate trading
volume with the intent to mislead market
participants
- disrupts information content of prices, lowers investor

confidence
- includes 1) dissemination of false/misleading information
2) transactions that deceive or would be
likely to mislead market participants by
distorting the price-setting mechanism of
financial instruments
Information-based manipulation
e.g./ spreading false rumors to induce
trading by others (pump and dump)
Transaction-based manipulation
actions that affect the pricing of
a security
wash
e.g./ giving the impression of activity
trades
securing a dominant/controlling position
in a financial asset to exploit and manipulate
the price of a related derivative cornering
standard 2B excludes legitimate trading
strategies
The key is intent
e.g./ I own 2 million shares of ABC. I am going to

sell them. I am going to move the price. I begin
to buy puts on ABC before I sell. On
expiration day, I sell hard into the close all
that I can.
Manipulation? Material nonpublic Info.?
Deceitful? Dishonest?
Duties to Clients
A. Loyalty, Prudence, Care

M/C has a duty of loyalty to their
clients and must act with reasonable care
and exercise prudent judgment
M/C must act for the benefit of their

clients and place their clients’ interests before
their employer’s or their own
- in some jurisdictions, duty of care may be fiduciary

3A is not a substitute (i.e. legal req.)
for any legal obligation
as per 1A more strict obligation applies


direct/indirect access to funds
- if M/C has custody of client assets,
heightened level of responsibility
Identifying the Actual Investment Client

- in short the beneficiary
e.g./ pension plans & trusts, client is not the
person who hires the PM, clients are the
beneficiaries of the fund
- may be no beneficiary (i.e. index fund)

- decisions do not have to be based on
beneficiary requirements, only to the mandate

Developing the Client’s Portfolio
- suitability
- disclose all potential conflicts of
interest to the client
- client guidelines are followed
- decisions are judged in the context
of the total portfolio ( duty is satisfied
w.r.t. a particular investment)
Soft Commission Policies

- payment of higher brokerage commissions
to purchase goods/services that don’t benefit
the client (disclosure)

Soft Commission Policies
directed brokerage client directs manager
to purchase goods/services for the client
(not a violation of 3A)
still must get best execution/best price
Proxy Voting Policies

- disclosure of when/how proxies are voted
Recommended Procedures for Guidance

Regular Account Info.
- quarterly reporting (funds, securities, transactions)
- custody disclosures
- client asset segregation/separation

- Client Approval – when in doubt about course
of action
- Firm Policies follow all applicable laws/rules

establish the investment objectives of
the client
consider all info. when taking actions
(suitability – client, security, portfolio)
Diversify
Regular reviews (investments ~ objectives)
Deal fairly with all clients w.r.t. investment
(e.g. allocating trades) actions

- Firm Policies
- disclose conflicts of interest
- disclose compensation arrangements
- vote proxies
- maintain confidentiality
- seek best execution
- place client interests first
B. Fair Dealing
M/C must deal fairly and objectively with
all clients when providing investment analysis,
making investment recommendations, taking
investment action, or engaging in other
professional activities
fairly ≠ equally; fairly means equitably
- fairly M/C must not discriminate against any clients

(disseminating recommendations, taking actions)
- clients may be at different levels of service and fees
(service levels/fees disclosed) these must not result
(available to all clients) in unfair treatment
B. Fair Dealing
Investment Recommendations
any opinion expressed by a M/C in

regard to purchasing, holding, or selling an investment
may be disseminated to customers/clients
only or to anyone outside
all clients must have a fair opportunity to act

on the recommendation
must prevent selective/discriminatory disclosure
clients should be aware of the type of
communication they will receive
B. Fair Dealing
Investment Recommendations
changes in recommendations more critical than
initial ones
communicated to all current clients, especially
those who have acted on the earlier advice
clients who place contrary orders should be advised
before the order is accepted
Investment Action
- treat all clients fairly in light of their investment
objectives
i.e./ allocation of new/secondary issues
- if oversubscribed, pro-rata basis

B. Fair Dealing
Investment Action
M/C should forgo personal allotments if
issues are oversubscribed
- if a family member is a similarly treated
client, that is ok!
disclose allocation procedures
M/C must never use allocated securities as
rewards or to gain benefit

Develop Firm policies (if none exist)
- guiding rule no preferred or favoured

status
B. Fair Dealing
- keep knowledge of impending recommendations to as few
people as possible
- shorten time between decision to issue and actual issue
- written guidelines for pre-dissemination behavior
- simultaneous disclosure – internally & to clients
- maintain a list of clients & their holdings
- develop/document trade allocation procedures that ensure:
priority of execution
- fairness to advisory clients
allocation of price
- timeliness/efficiency in
order execution
- accurate M/C records

B. Fair Dealing
Allocations/ all orders time stamped
orders processed FIFO basis
- bundling when efficient
process to determine execution prices
and partial fills (for grouped trades)
group orders all get same execution price
pro-rata distribution on partial fills
allocation by client rather than portfolio
manager
B. Fair Dealing
disclose allocation procedures

- if the allocation process is unfair,
disclosure does not exempt M/C from 3B
systematic account review

- suitability?
- preferential treatment?
disclose levels of service

- should not be offered selectively
C. Suitability
- when M/C are in an advisory relationship
with a client, they must
investment experience
a) make reasonable inquiry risk/return objectives IPS
financial constraints
prior to investment recommendation
taking investment action
& reassess and update regularly
client’s financial situations
b) determine suitability
client’s written objectives
c) in the context of the whole portfolio
C. Suitability
- suitability does not mean no losses
- if advisory relationship does not exist, M/C may

not be in a position to determine suitability
i.e. unsolicited orders
- if M/C knows such an order is
unsuitable, should get client to acknowledge that
awareness
Managing to an Index or Mandate

- no advisory relationship
- decisions should be consistent with the
mandate
C. Suitability
- when managing a portfolio to a specific
mandate, strategy or style, must act in accordance
with that mandate
Guidance much of this Standard covered in Port. Mgmt.

study session
- Investment Policy Statement
- Client’s Risk Profile risk tolerance
- Update regularly
also/
- Diversification
C. Suitability
- Investment Policy Statement
- review Port. Mgmt.
- Regular updates/reviews
- Suitability test policies
- impact on diversification
- fit with risk tolerance
- fit with investment objectives

- when communicating investment performance
information, M/C must make reasonable efforts to
ensure that it is fair, accurate, and complete
- credible performance information

- avoid misstating or misleading
- both in presentation and measurement
- can not state/imply that clients will experience
a past performance level
- analysts promoting hit ratio
must present accurately and completely
GIPS (next 2 readings)
without GIPS/
include all accounts
include terminated accounts
gross or net of fees, taxes, inflation
maintain data and records used to
calculate performance
M/C must keep information about current,
former, and prospective clients confidential unless:
1) information concerns illegal activities
on the part of the client
2) disclosure is required by law
3) client or prospective client permits it
if applicable laws require confidentiality, even if

above applies, M/C must follow law.
many firms will have policies about
storing client info. on personal laptops or portable
drives
this standard does not prevent the M/C
from cooperating with CFA-PCP if requested to
supply client account info.

- don’t disclose anything
- if its information outside of the scope
of the confidential relationship and does not
involve illegal activity, may be ok!
Duties to Employers
A. Loyalty
in matters related to their employment, M/C
must act for the benefit of their employer and
not 1) deprive employer of their skills and
abilities
2) divulge confidential information
3) cause harm to their employer
e.g. – injure the firm, deprive it of
profit, deprive it of M/C skills/
abilities
client
interest
> employer
interest
> M/C interest
(aside from personal/family
obligations)
A. Loyalty
Employer Responsibilities
Note/ Employers are not obligated to

adhere to the Code and Standards
- M/C are however
firms should not adopt/develop conflicting practices
Independent Practice
M/C must abstain from independent
competitive activity that could conflict with the
interests of their employer
- does not preclude M/C from doing so, but
does require disclosure of intent to employer
and their ok!
A. Loyalty
Leaving an Employer
must continue to act in employer’s best
interest until resignation takes effect
- if the M/C is leaving to compete (ok by the way)

must not 1) appropriate trade secrets
2) misuse confidential information
3) solicit employer’s clients prior to leaving
4) take client lists
- is ok for M/C to make arrangements while still

employed
A. Loyalty
Leaving an Employer
- does not prohibit experience or knowledge

gained at one employer from being used at
another
- records or work performed that was
codified are off limits
- does not prevent M/C from contacting previous

clients as long as:
the names do not come from a list
there is no ‘agreement’ limiting
contact
A. Loyalty
Whistle blowing – violating 4A is permitted
when doing so protects clients or the integrity of
the markets
Nature of Employment
M/C may be independent contractor
duties will be governed by the
agreement between M/C & company, not the
standard
- competition policy (non compete)
- termination policy
- incident reporting procedures (whistle blowing)
- employee classification – how policies apply
to each class
B. Additional Compensation Arrangements

M/C must not accept any gifts, benefits,
compensation, or consideration that competes with or
might reasonably be expected to create a conflict
of interest with their employer’s interests unless
they obtain written consent from all parties
involved
- in short, get permission before accepting
e.g./ client offers extra bonus (free use of

their ski chalet) if a certain target return
is achieved
M/C must make reasonable efforts to
detect and prevent violations of applicable laws,
rules, regulations and the C/S by anyone subject
to their supervision or authority
- whether or not they are M/C
- delegating supervisory duties is no relief from 4C
Detection Procedures
- reasonable efforts – establishing/implementing
written compliance procedures
- periodic reviews
if a violation is not detected despite these
efforts, would not be a violation of 4C.
- however, if M/C knows that procedures
are not being followed, merely having them would
not be enough
Compliance Procedures
M/C must understand what makes an
adequate compliance system
those designed to M/C must make reasonable
meet industry standards efforts to close any gaps
and regulatory compliance from current to ‘adequate’
along with the C/S - then make reasonable effort
to ensure they are monitored
and enforced
Compliance Procedures
- once a violation arises, M/C must
promptly initiate an investigation to assess extent
(employee placed on restricted access pending the outcome)
Inadequate Procedures
- inform senior mgmt. & recommend corrective
action
- if M/C feels they cannot discharge
supervisory duties due to inadequate procedures,
they must decline the responsibility
Enforcement of Non-Investment Related Policies
- enforced equally
e.g./ attendance, acceptable workplace actions
principles – recommend employer adopt a Code of Ethics

implementation – put in place specific policies/procedures
to ensure compliance
- provide the Code to clients
- implement education/training programs
- tie incentives to adherence
Adequate compliance procedures/
- identify situations in which violations are likely to
occur and develop compliance procedures that are:
clearly written and accessible the Code of
easy to understand Ethics
designate a compliance officer (authority + resources)
clear hierarchy of supervision (who’s watching who)
outline scope of procedures along with procedures
to monitor/test those procedures
procedures for reporting violations
once system is in place, supervisor should:
disseminate to appropriate personnel

periodically review/update
periodically review employees
enforce procedures if a violation occurs
once a violation is discovered, supervisor should
respond promptly
investigate to determine scope
restrict employee actions pending outcome
Investment Analysis, Recommendations, and Actions
M/C must 1) exercise diligence, independence

and thoroughness in analyzing investments,
making investment recommendations, and taking
investment action
2) have a reasonable and adequate
basis, supported by appropriate research and
investigation, for any investment analysis,
recommendation, or action
Defining Diligence and Reasonable Basis

level and thoroughness · based on a set of facts
of the information reviewed known and understood
- differs with product/security at the time
being analyzed

Defining Diligence and Reasonable Basis
· level depends on the · formed through a balance
support and resources of what is known and what
provided by M/C employer resources have been provided
Using Secondary or 3rd Party Research

research conducted research conducted outside
by someone else in the the firm
firm
M/C must make reasonable efforts to determine

if this research is sound

Using Secondary or 3rd Party Research
- assess/ assumptions used

rigor of the analysis
date/timelines of the research
evaluation of the objectivity and
independence of the conclusions
when research vendors are chosen from above,

M/C may use the information in good faith
Quantitatively Oriented Research

- must understand parameters used in models,
assumptions and limitations

Quantitatively Oriented Research
- should make every effort to test the
output of investment models before incorporating
into recommendations
Developing Quantitatively Oriented Techniques

M/C involved in the development of the
models/algorithms must understand the technical
aspects
Selecting External Advisors

M/C must review external managers as
diligently as they review securities

Selecting External Advisors
standardized criteria for reviewing external
advisors
review their Code of Ethics
understand their compliance and
internal control procedures
assess the quality of their published
performance record
review their investment process and how
well they hold to their stated strategy

Group Research and Decision Making
output of group is the consensus of the
group
all names are on the report
if M/C does not agree but the opinion
has a reasonable basis, is independent
and objective, no need to dissociate

- a policy that research outputs have a
basis that can be substantiated as
reasonable and adequate

internal review before release

develop review guidelines that establish
the necessary rigor, accuracy & quality
hurdles
for research
for model testing
for assessing external advisors
for assessing 3rd party information providers
B. Communication with Clients and Prospective Clients
M/C must disclose the basic format and general

principles of the investment process they use to
analyze investments, select securities, and
construct portfolios and must promptly disclose any
changes that might materially affect those processes
use reasonable judgment in identifying

which factors are important to their investment
analysis, recommendations, or actions and include those
factors in communications with clients & prospective clients
distinguish between fact and opinion in the

presentation of investment analysis & recommendations

communication
M/C · clear client

understanding of/
· frequent
updates instrumental factors
· thorough
opinion vs. fact
Informing Clients of the Investment Process

M/C must adequately describe how the investment
decision-making process is conducted + any changes
what constitutes a suitable inv. recomm.

(usually in terms of E(Rp) + σp)
if external advisors are used, what specialization

or diversification expertise

Different Forms of Communication
written, oral, media broadcast, social media,
e-mail, webinar
M/C must ensure all clients are treated fairly

in terms of accessibility
if content of communication is in capsule
form (i.e. short), M/C should notify clients that
additional detail/analysis is available
M/C must outline significant risks and

limitations of the analysis

Identifying Limitations of Analysis
risk disclosures relate to what was known
at the time of release
having no knowledge of a risk/limitation that
eventually results in a loss is not a violation
of 5(B)
Distinction Between Facts and Opinions

most common separation of past & future
fact opinion
quantitative conclusions – separate fact from
statistical conjecture
Distinction Between Facts and Opinions
M/C may be in violation by failing to

identify limitations of statistically developed
projections merely an estimate of future results
research review process (internal peer reviews)
1 word Defensible
C. Record Retention
M/C must develop and maintain appropriate
records to support their investment analyses,
recommendations, actions and other investment-related
communications with clients and prospective clients
- either in hard copy or electronic form

e.g./ personal notes from company meetings
press releases/presentations from covered companies
computer-based model outputs/inputs
risk analysis of a security on a portfolio
notes from meetings with clients
C. Record Retention
Records are Property of the Firm
all M/C output while employed

cannot take originals/copies when M/C leaves without
M/C must re-create the research at the consent
new firm along with all the supporting records
Local Requirements
regulators often impose requirements with the required
time frame for retaining records (CFA 7 years)

responsibility to maintain records rests with
the firm M/C must archive research notes
Conflicts of Interest
M/C must make full and fair disclosure

of all matters that could reasonably be expected to
impair their independence and objectivity or interfere
with respective duties to their clients, prospective
clients, and employer
M/C must ensure that such disclosures

are prominent, are delivered in plain language, and
communicate the relevant information effectively
- best practice is to avoid real/perceived
conflicts
- if avoidance is not possible, M/C must ensure
that conflicts are communicated effectively
Disclosures of Conflicts to Employers

M/C must provide enough information for
the employer to assess the impact
e.g./ ownership of stocks analyzed may be explicitly

prohibited by an
participation on outside boards
employer
may interfere with rendering
unbiased investment advice
Disclosures of Conflicts to Employers
- typically, the same situations that would
generate conflicts with clients
- the mere appearance of a conflict could
create problems for M/C & their employers
- if a conflict occurs inadvertently, M/C
must report promptly
Disclosures to Clients
M/C must be, and be seen as, objective
- disclose relationship between an issuer and
M/C or employer – directorship, ownership,
broker/dealer market making, etc...
Disclosures to Clients
- fee arrangements, subadvisory agreements &
other non-standard fee structures
agreements in which the firm benefits
directly from investment recommendations
Cross-Departmental Conflicts
e.g./ marketing/sales
vs. analyst
broker/dealer
Conflicts with Stock Ownership

M/C ownership of stock in companies
being recommended to clients
Conflicts with Stock Ownership
- prohibition is unfair, therefore beneficial
ownership disclosure is required
Conflicts as Director
conflict between duty owed to clients
vs. to shareholders
option compensation vs. objectivity
material nonpublic information
M/C should be isolated from those making
investment decisions
- disclose special compensation agreements

that might conflict with client’s interests
e.g. bonuses based on short-term performance

include information on compensation
packages in promotional literature
investment transactions for clients and
employers must have priority over investment
transactions in which a M/C is the beneficial owner
Avoiding Potential Conflicts

M/C is free to invest personally as long as:
1) the client is not disadvantaged by any trade
2) M/C does not benefit personally from trades
undertaken for clients
3) M/C complies with applicable regulatory requirements
- extends to trades that may run counter to current

client recommendations
Personal Trading Secondary to Trading for Clients
- objective is to prevent personal transactions
from adversely affecting the interests of clients
and employers
Standards for Nonpublic Information

M/C may have knowledge of pending
transactions or may have knowledge of material
nonpublic information
M/C would be prohibited from acting on or

conveying such information
Impact on All Accounts with Beneficial Ownership
M/C can execute trades in accounts for which
they are beneficial owner only after clients and
employers have had adequate opportunity to act on
a recommendation
- family accounts that are client accounts
should be treated like any other account

Limited participation in equity IPOs
- M/C participation may be seen as
taking an opportunity away from a client
an incentive to make future favourable decisions
to the party providing the opportunity
Restrictions on Private placements
- same logic as IPOs
Establish blackout/restricted periods

- prior to trades for clients
- avoid front-running
- should cover all involved in the decision-making
process
- not practical for large firms
Reporting requirements
Disclosure of holdings in which the
employee has a beneficial interest
Reporting requirements
- disclosure should be made upon commencement of job
and at least annually
Provide duplicate confirmations of transactions
- verification of the timing of transactions versus
only knowledge of holdings
- self-policing/monitoring
Preclearance procedures
M/C should examine all planned personal trades
and avoid potential conflicts
Disclose personal investing policies to clients
C. Referral Fees
M/C must disclose to their employer, clients,
and prospective clients, as appropriate, any compensation,
consideration, or benefit received from or paid to
others for the recommendations of products or services
Product 1 M/C must

fee advise the client
recommends BEFORE entry
M/C client into any formal
agreement
fee
Service 1
flat-fee or %’age?
one-time or ongoing? disclose
cash or soft dollars?
Responsibilities as a CFA Institute M/C
A. Conduct as M/C in the CFA Program
M/C must not engage in any conduct that

compromises the reputation or integrity of CFA
Institute or the CFA designation or the integrity,
validity, or security of the CFA examinations
Confidential Program Information

- candidates prohibited from disclosing
confidential material gained during the exam process
- specific details of questions appearing on
the exam
- broad topical areas and formulas tested or not
tested on the exam
A. Conduct as M/C in the CFA Program

Confidential Program Information
- all aspects of the exam are considered
confidential until CFA releases them publicly
Additional CFA Program Restrictions calculator

- violating any testing policies personal belongings
is a violation of 7(A) Candidate Pledge
Expressing an Opinion
M/C are free to disagree and express their
disagreement with CFA on policies/procedures
- cannot disclose content-specific information
however
B. Reference to CFA Institute, the CFA designation, and

the CFA Program
when referring to CFA Institute, CFA Institute

Membership, the CFA designation, or candidacy in the
CFA Program, M/C must not misrepresent or
exaggerate the meaning or implications of membership
in CFA Institute, holding the CFA designation, or
candidacy in the CFA Program
- meant to prevent promotional efforts that make

promises or guarantees that are tied to the CFA
designation

the CFA Program
- cannot imply that due to holding CFA,
clients can expect superior performance
CFA Institute Membership

regular & affiliate who have met
membership requirements
once accepted as a member, to maintain
status remit annually a Professional Conduct
statement
pay applicable membership dues
- fail to do or , no longer active member

- must not represent themselves as such

the CFA Program
Using the CFA designation
- those who have earned it (?), may use
the trademarks ‘Chartered Financial Analyst’ or ‘CFA’
- must also satisfy membership
requirements to maintain their right to use
the designation
$/yr.
- fail to meet or earlier, forfeit right to
use the CFA designation
- must not present yourself as a CFA

charterholder

the CFA Program
Referring to Candidacy in the CFA Program
- must clearly state you are a candidate
and must not imply achievement of any partial
designation
candidate if/ application for registration has

been accepted and are enrolled to
sit for a specified exam
have sat for an exam but results
are not out yet

the CFA Program
Referring to Candidacy in the CFA Program
- never state/imply partial designation or
cite an expected completion date
- if you pass all 3 levels in consecutive
years, you can say so, but you can’t say it gives
you superior ability
Proper use of the CFA marks

- must be used only after a name or as an
adjective
- cannot be used as part of the name of a
firm
Introduction to the Global Investment Performance Standards (GIPS®)
a. explain why the GIPS standards were created, what parties the GIPS
standards apply to, and who is served by the standards;
b. describe the key concepts of the GIPS standards for firms;
c. explain the purpose of composites in performance reporting;
d. describe the fundamentals of compliance, including the recommendations of

the GIPS standards with respect to the definition of the firm and the firm’s
definition of discretion;
e. describe the concept of independent verification.

Introduction to GIPS
Page 1
Mission - to promote ethics & integrity and instill trust
LOS a, b
by achieving universal demand for compliance - explain
by asset owners, adoption by asset managers, - describe
and support from regulators
- meant to overcome past lack of comparability
1/ Representative accounts - selecting a top-performing portfolio to

represent a firm’s overall investment results for a
specific mandate
2/ Survivorship bias - presenting an average performance history

that excludes terminated portfolios due to weak
performance
3/ Varying Time Periods - presenting performance for a selected

time period during which the mandate produced excellent
returns or outperformed its benchmark
Page 2
GIPS - practitioner-driven set of ethical principles that LOS a, b
establish a standardized, industry-wide approach - explain
for investment firms to follow in calculating and - describe
presenting their historical investment results to prospective clients
ensure fair presentation and full disclosure of investment results
Objectives: promote investor interests and instill investor confidence
ensure accurate and consistent data

obtain worldwide acceptance of a single standard for calculating
and presenting performance
promote fair global competition among investment firms
promote industry self-regulation on a global basis

Page 3
Who can claim compliance? LOS a, b
- any firm that actually manages assets - explain
- describe
- asset owners may comply if they compete for business
- if not, but report their performance to an oversight body,
can comply with ‘GIPS for Asset Owners’
- compliance is firm-wide, it cannot be achieved on a single

product or composite (comply fully or don’t, no partial
compliance)
- compliance is voluntary
Who benefits from compliance? - asset managers and their prospective

clients and asset owners and their oversight bodies
Page 4
Composites/ an aggregation of one or more portfolios LOS c
managed according to a similar investment - explain
mandate, objective, or strategy
- all actual, fee-paying, discretionary portfolios must be included in

at least one composite
- determination of the composite for a portfolio must be done

before the fact, not after
Definition of the Firm: The firm should adopt the broadest, LOS d
- describe
most meaningful definition of the firm.
- should include all geographical offices operating under the
same brand name, regardless of the actual name of the
investment management company
Page 5
Definition of discretion: establishes criteria to judge LOS d
which portfolios must be included in a - describe
composite and is based on a firm’s ability to implement
its investment strategies
- client restrictions may prevent the proper implementation of

the strategy
LOS e
Verification/ voluntary
- describe
- an independent 3rd party firm must do it (firm cannot verify
itself)
- verification is firm-wide, not on a specific composite
- does not ensure accuracy of any specific composite presentation

Ethics Applications
a. evaluate practices, policies, and conduct relative to the CFA Institute Code of
Ethics and Standards of Professional Conduct;
b. explain how the practices, policies, and conduct do or do not violate the CFA
Institute Code of Ethics and Standards of Professional Conduct.
Ethics – C & S - Review

Review - 1
Professionalism/
A. Knowledge of the Law C/S always, unless MS
offer
B. Independence/Objectivity no gift/benefit/compensation solicit
that could reasonably compromise I/O accept
C. Misrepresentation practice, credentials, qualifications,

performance record, intended use of 3rd party
managers
D. Misconduct – no act that reflects poorly on

professional reputation, integrity, competence
(dishonesty, fraud, deceit)
Review - 2
Integrity of Capital Markets/
A. Material Non-Public Information – cannot act, or cause
others to act on it
likely effect on price source
more ambiguous, less likely less reliable, less likely
Note: Analyst Report, using Mosaic Theory, is not a violation,

and can be shared with clients only before being made
public
B. Market Manipulation information based intent to

· distort prices transaction based mislead market
· inflate volume participants
Review - 3
Duties to Clients/ reasonable care
if custody of
A. Loyalty, Prudence & Care prudent judgment assets, heightened
confidentiality level of responsibility
market
[client – employer – M/C]
integrity
beneficiary (suitability)
mandate
B. Fair Dealing – fair ≠ equal, fair = equitable
investment analysis
recommendations at the same level
action of service
OK to have different levels of service or fees
Review - 4
Duties to Clients/
C. Suitability KYC - know your client risk/ret. obj./reg.
IPS constraints
KYM - know your mandate
in the context
of the whole portfolio
fair
cannot guarantee
D. Performance Presentation accurate
performance
complete
unless 1/ illegal activity on part of client
2/ required by law
3/ client permits it
Review - 5
Duties to Employer
A. Loyalty – act for benefit of employer
- cannot compete with employer (unless you have
permission)
- if leaving to compete: cannot
· take trade secrets or confidential information
ok as long as · solicit clients or take customer lists
names do not · take work that was codified
come from a list & there
is no agreement in place restricting that
B. Additional Compensation: from clients to M/C any compensation

NOT: from employer that might reasonably
to M/C create a conflict
of interest
Review - 6
Duties to Employer
C. Responsibilities of Supervisors reasonable effort to detect
or prevent violations of - laws
- rules/regulations
by anyone subject to supervision - C&S
(M/C or not)
- delegation is no relief
Investment Analysis, Recommendations, Action

A. Diligence, Reasonable Basis
- exercise diligence, independence, thoroughness
- reasonable and adequate basis (supported by fact)
B. Communication with Clients

· disclose investment process (general principles) – and any
· distinguish between fact & opinion changes to it
or people
Review - 7
Investment Analysis, Recommendations, Analysis
C. Record Retention hard copy or electronic (property of firm)
appropriate records to support investment
analysis, recommendations, actions, communication
with clients
can’t take copies w/o consent
A. Full Disclosure – full disclosure of all matters that could
reasonably be expected to impair indep./obj.
- to clients and employers
(fee arrangements)
B. Priority of Transactions clients – employers – M/C

M/C free to invest personally (but client can’t be
family accounts that are client disadvantaged by it)
accounts, treated as client accounts
Review - 8
C. Referral Fees M/C must disclose to employers/clients
any compensation, consideration, benefit received from
or paid to others for the recommendation of
products or services
Responsibility as a CFA M/C

A. Conduct as a M/C in the program – must not engage in
any conduct that compromises the integrity of CFAI
or the CFA designation, or the integrity of the exams
specific questions, broad topical

areas, formulas tested/not tested
B. Reference to CFAI, CFA designation, or CFA Program

- must not imply partial designation
- must not cite a completion date
Review - 9
Regular Compensation vs. Additional Compensation
Employer Client potential
conflict of
M/C M/C interest?
- client migration bonus
- reasonably impair I/O? (Y) before the (N) after the
fact fact
Y N - permission in - notification/
disclose no disclosure writing disclosure
Fee-sharing vs. Referral Fee vs. Referral fee/

no disclosure disclose employer fee sharing
(before client - still a referral
entry to an
prospective fee
agreement)
clients
- given or received
+ nature (i.e. flat fee, %age
one-time, continuing)

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Level I - Ethical and Professional Standards

Ethics and Trust in the Investment Profession 2

Code of Ethics and Standards of Professional Conduct 9

Guidance for Standards I-VII 15

Introduction to the Global Investment Performance Standards

© markmeldrum.com. All rights reserved.

Ethics and Trust in the Investment Profession

b. describe the role of a code of ethics in defining a profession;

c. describe professions and how they establish trust;

d. describe the need for high ethical standards in investment management;

e. explain professionalism in investment management;

f. identify challenges to ethical behavior;

g. compare between ethical and legal standards;

h. describe a framework for ethical decision making.

- moral/ethical principles - beliefs regarding what is good,

- may be individual as well as shared beliefs regarding

- ethical conduct - behavior that follows moral principles

e.g./ honesty, fairness or justice, diligence, respect for the rights

expectations regarding member behavior

- to protect innocent members (limit potential harm)

Ethics & Professionalism

- in any given profession, a code of ethics communicates the

Professionalism in Investment Mgmt.

2/ Professions provide a service to society - support economic activity

3/ Professions are client focused - place the integrity of the

4/ Professions have high entry standards - thus membership is a

5/ Profession possesses a body of expert knowledge

6/ Professions encourage and facilitate continuing education

8/ Professions are collegial

9/ Professions are recognized overseeing bodies - not-for-profit

10/ Professions encourage the engagement of members - through

- investment management profession meets most, but currently

CFA Institute as an Investment Management Professional Body

- uphold the reputation of their profession

- ethical dilemmas should not avoid responsibility for

Investment Industry & Ethics

- capital flows more efficiently when financial market

- higher trust lowers the cost of capital for borrowers

- financial markets/investment industry are built on trust

- reputation effect - clients are attracted to firms with

Challenges to Ethical Conduct

- I am honest vs. do others see me as honest?

2. Underweighting the situational influences

external factors that shape our

3. Limitations to organizational compliance

- insufficient for ensuring ethical decision

Ethical vs. Legal Standards

laws & regulations - vary across countries/jurisdictions

- usually insufficient to ensure

Ethical Decision-Making Frameworks

- increase the ability (and motivation) to act ethically

e.g./ Identify - relevant facts, stakeholders and duties owed,

Consider - situational influences, additional guidance,

Decide and Act

Reflect - was the outcome as anticipated? Why/Why not?

Code of Ethics and Standards of Professional Conduct

a. describe the structure of the CFA Institute Professional Conduct Program

c. explain the ethical responsibilities required by the Code and Standards,

Professional Conduct Program

Professional Conduct Disciplinary Review

responsible for the enforcement of

3) CFA staff through media, regulatory notices