Cfa Level I Ethics Review Class

cfa level I
ETHICAL AND PROFESSIONAL

STANDARDS
REVIEW CLASS
Ethics and Trust in the
Investment Profession
CFA LEVEL I Ethics and Trust in the Investment Profession
Question 1
Ethical conduct is most likely behavior that:
A. is perceived to be beneficial as per society’s ethical

expectations.
B. conforms to expectations as laid out by laws and regulations.
C. simply considers both the direct benefit and indirect
consequences on others.
1
Solution -
A is correct.
Ethical conduct includes those actions that are perceived as beneficial

and conforming to the ethical expectations of society.
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Question 2
An investment fund manager has a finance degree and over 20

years of experience working for a top-ranking asset management
firm. Based only on this information, could the investment fund
manager most likely claim to be part of a profession?
A. Yes, as part of the industry, he is providing a service to others.

B. Yes, a person working in this industry requires specialized
knowledge and skills.
C. No.
3
Solution -
C is correct.
For the investment fund manager to claim he is part of a

profession, the activity must be based on specialized knowledge
and skills, must include service to others, and must be practiced by
members who share and agree to adhere to a common code of
ethics. Investment management is based on providing service to a
firm’s clients and also requires specialized knowledge and skills, but
it would not be considered a profession unless there exists a
common code of ethics among similar investment fund managers.
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Question 3
When an otherwise honest person allows the promise of a bonus

to negatively influence her behavior, it is most likely an example
of what type of ethical challenge?
A. Compliance oversimplification
B. Overconfidence bias
C. Situational influence
5
Solution -
C is correct.
Discussions of receiving a bonus can have a disproportionate

influence on our decision making because it can cause us to focus
on short-term outcomes rather than long-term desired objectives.
This is an example of a situational influence, which often causes
people to not consider other important considerations when
making decisions.
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Question 4
Which of the following is most likely an example of an

overconfidence bias leading to poor ethical decision making?
A. “I’m aware of my ethical obligations.”

B. “I’m sure I did the right thing.”
C. “I’m smart; that will keep me out of trouble.”
7
Solution -
C is correct.
An overconfidence bias is shown by thinking that your intelligence

level will prevent you from acting in an unethical manner. A person
who understands ethical behavior, no matter her intelligence level,
can often decipher unethical behavior by looking at the long-term
consequences of improper actions by an individual.
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Question 5
The relationship between an investment professional and her

clients is predominately based on trust, most likely because the
investment professional:
A. has specialized knowledge, leading her to have more power.

B. has access to information on which to base investment
decisions.
C. sells or gives advice related to tangible products and services.
9
Solution -
A is correct.
Investment professionals have access to specialized knowledge and

often have better access to information that gives them an
advantage and more power than the client. Clients expect their
advisers to use this knowledge and information to their benefit, not
for the investment professional to take advantage of them.
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Question 6
What is most likely a critical aspect of the Consider phase of an

ethical decision-making framework?
A. Seeking additional guidance

B. Distinguishing duties to stakeholders
C. Contemplating your decision
11
Solution -
A is correct.
Seeking additional guidance in the Consider phase of the ethical

decision-making framework is a critical step in viewing the situation
from different perspectives. It is best to seek guidance from
someone who is not affected by the same situational influences or
behavioral biases to provide a fresh perspective. Additional
guidance can be obtained from the firm’s policies and procedures
and the CFA Institute Code and Standards.
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Question 7
If you are seeking guidance from the firm’s code of ethics or

written policies, your actions most likely reflect which phase of an
ethical decision- making framework?
A. Consider
B. Decide
C. Reflect
13
Solution -
A is correct.
If you are seeking guidance from the firm’s code of ethics or

written policies, you are in the Consider phase of the ethical
decision- making framework. This phase involves taking time to
consider the situation influences as well as personal behavioral
biases that could affect your thinking and decision making. During
this phase, you may also seek guidance from such trusted sources
as the firm's compliance department or outside counsel.
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Question 8
If you are characterizing clients, family, colleagues, and market

participants and the duties owed to them, you are most likely in
which phase of an ethical decision-making framework?
A. Identify
B. Consider
C. Decide
15
Solution -
A is correct.
The Identify phase is typically the initial phase of the ethical

decision-making framework. In this phase, you will identify the
important facts available as well as those facts that you wish were
available to develop a complete understanding of the situation. In
this phase you also identify the stakeholders—clients, family,
colleagues, market participants, and others—and the duties to
them.
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Question 9
Which of the following is least likely a phase in an ethical

decision-making framework?
A. Consideration of situational influences, additional guidance, and

alternative actions
B. Multiple iterations of analysis
C. Reflection on the outcome versus what was anticipated
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Solution -
B is correct.
Multiple iterations of analysis is not a phase in the ethical decision-

making framework. The ethical decision-making process includes
multiple phases, and the process of developing the framework
involves multiple iterations. The iterative aspect of developing the
framework is essential to the process, but it is not a phase in the
ethical decision- making process.
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Question 10
The benefits of an ethical decision-making framework would least

likely include:
A. limiting unintended consequences.

B. making wise decisions.
C. focusing on immediate consequences.
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Solution -
C is correct.
The benefits of an ethical decision-making framework are least

likely to include focusing on immediate consequences. The
framework allows the decision maker to focus on multiple
perspectives and does not limit the decision maker to a short-term
focus.
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Code of Ethics and Standards of
Professional Conduct
Guidance for Standards I–VII

CFA LEVEL I Code of Ethics and Standards of Professional Conduct
Question 11
Which of the following least likely reflects the two primary principles
of the CFA Institute Rules of Procedure for Proceedings Related to
Professional Conduct?
A. Public disclosure of disciplinary sanctions

B. Fair process to the member and candidate
C. Confidentiality of proceedings
21
Solution -
A is correct.
Because the two principles of the Rules of Procedure for Proceedings

Related to Professional Conduct are confidentiality of proceedings and
fair process to the member and candidate.
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Question 12
Which of the following groups is most likely responsible for

maintaining oversight and responsibility for the Professional Conduct
Program (PCP)?
A. Disciplinary Review Committee

B. CFA Institute Board of Governors
C. Professional Conduct Division
23
Solution -
B is correct.
All CFA Institute members and candidates enrolled in the CFA Program
are required to comply with the Code and Standards. The CFA Institute
Board of Governors maintains oversight and responsibility for the
Professional Conduct Program (PCP).
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Question 13
Disclosure of confidential CFA exam information will most likely be

detected by the Professional Conduct staff through:
A. analysis of Proctor Reports.

B. annual Professional Conduct Statements.
C. monitoring online and social media.
25
Solution -
C is correct.
Professional Conduct inquiries come from a number of sources including

the monitoring of online and social media to detect disclosure of
confidential exam information.
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Question 14
Sanctions imposed by CFA Institute for violations of the CFA Institute

Code of Ethics or Standards of Professional Conduct least likely include:
A. revocation of a CFA Charter.

B. monetary fines.
C. public censure.
27
Solution -
B is correct.
Sanctions available to CFA Institute do not include monetary fines.

However, sanctions imposed by CFA Institute may have significant
consequences; they include public censure, suspension of membership
and use of the CFA designation, and revocation of the CFA charter.
Candidates enrolled in the CFA Program who have violated the Code and
Standards or testing policies may be suspended or prohibited from
further participation in the CFA Program.
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Question 15
Which of the following is not a component of the CFA Institute Code of

Ethics?
A. Practice and encourage others to practice in a professional and

ethical manner that will reflect credit on themselves and the
profession.
B. Promote financial integrity and seek to prevent and punish abuses in
the financial markets.
C. Place the integrity of the investment profession and the interests of
clients above their own personal interests.
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Solution -
B is correct.
Punishing abuses in the financial sector is not included in any of the six
components of the CFA Code of Ethics.
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Investment Analysis, Recommendations and Actions – V (B) Communication with Clients and
Prospective Clients
Members and Candidates must:
1. Disclose to clients and prospective clients the basic format and general principles of the investment
processes they use to analyze investments, select securities, and construct portfolios and must
promptly disclose any changes that might materially affect those processes.
2. Disclose to clients and prospective clients significant limitations and risks associated with the
investment process.
3. Use reasonable judgment in identifying which factors are important to their investment analyses,
recommendations, or actions and include those factors in communications with clients and prospective
clients.
4. Distinguish between fact and opinion in the presentation of investment analyses and
recommendations.
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Question 16
Which of the following statements related to requirements for the CFA

Institute Standards of Professional Conduct Standard V(B)–
Communication with Clients and Prospective Clients is least likely
accurate? The standard requires members and candidates to:
A. distinguish between fact and opinion in the presentation of
investment analysis and recommendations.
B. divulge the number of investment related personnel responsible for
external communication.
C. disclose the basic format and general principles of the investment
process.
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Solution -
B is correct.
The CFA Institute Standards of Professional Conduct Standard V(B)–

Communication with Clients and Prospective Clients does not limit the
type or number of staff responsible for external communication.
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Duties to clients – III (D) Performance Presentation
When communicating investment performance information, Members and Candidates must make
reasonable efforts to ensure that it is fair, accurate, and complete.
Prospective Clients
investment process.
recommendations, or actions and include those factors in communications with clients and
prospective clients.
recommendations.
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Question 17
Which of the following is least likely part of the CFA Institute Standards
of Professional Conduct, Standard V(B)–Communication with Clients
and Prospective Clients? Members and candidates must:
A. disclose to clients and prospective clients significant limitations and

risks associated with the investment process.
B. distinguish between fact and opinion in the presentation of
investment analysis and recommendations.
C. make reasonable efforts to ensure that when communicating
investment performance information it is fair, accurate, and
complete.
35
Solution -
C is correct.
The statement, “When communicating investment performance

information, Members and Candidates must make reasonable efforts to
ensure that it is fair, accurate, and complete.” can be found in The CFA
Institute Standards of Professional Conduct, Standard III–Duties to
Clients (D) Performance Presentation. It is not part of Standard
V–Investment Analysis, Recommendations, and Actions (B)
Communication with Clients and Prospective Clients.
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Integrity of Capital market – II (A) Material Non Public Information
Members and Candidates who possess material non public information that could affect the value of an
investment must not act or cause others to act on the information.> Information that is ambiguous as to
its likely effect on price may not be considered material. > Under the so-called mosaic theory, reaching an
investment conclusion through perceptive analysis of public information combined with non-material non
public information is not a violation of the Standard.
Integrity of Capital market – II (B) Market manipulation
Members and Candidates must not engage in practices that distort prices or artificially inflate trading
volume with the intent to mislead market participants.
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Question 18
Which of the following is least likely part of the CFA Institute Standards
of Professional Conduct, Standard II–Integrity of Capital Markets?
Members and candidates:
A. must not engage in practices that distort prices or artificially inflate
trading volume with the intent to mislead market participants.
B. must promote the integrity and viability of the global capital markets
for the ultimate benefit of society.
C. who possess material nonpublic information that could affect the
value of an investment must not act or cause others to act on the
information.
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Solution -
B is correct.
The Code of Ethics of CFA Institute states that Members of CFA Institute
(including CFA charterholders) and candidates for the CFA designation
(“Members and Candidates”) must promote the integrity and viability of
global capital markets for the ultimate benefit of society. It is not part of
the CFA Institute Standards of Professional Conduct, Standard
II– Integrity of Capital Markets.
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Question 19
In the CFA Institute Standards of Professional Conduct, Standard III–
Duties to Clients most likely includes which of the following
subsections?
A. Knowledge of the Law

B. Independence and Objectivity
C. Performance Presentation
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Solution -
C is correct.
Performance Presentation is a sub-section of Standard III– Duties to

Clients. The other sub-sections include: Loyalty, Prudence and Care, Fair
Dealing, Suitability, and Preservation of Confidentiality.
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Prospective Clients
investment process.
recommendations, or actions and include those factors in communications with clients and prospective
clients.
recommendations.
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Question 20
Which CFA Institute Standard of Professional Conduct most likely

includes a sub-section entitled “Communication with Clients and
Prospective Clients”?
A. Duties to Clients
B. Investment Analysis, Recommendations, and Actions
C. Conflicts of Interest
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Solution -
B is correct.
Standard V–Investment Analysis, Recommendations, and Actions

includes the sub-section Communication with Clients and Prospective
Clients. The other sub-sections within Standard V include Diligence and
Reasonable Basis and Record Retention.
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Duties to Employers – IV (B) Additional Compensation Arrangements
Members and Candidates must not accept gifts, benefits, compensation, or consideration that competes
with or might reasonably be expected to create a conflict of interest with their employer’s interest unless
they obtain written consent from all parties involved.
Question 21
“Additional Compensation Agreements” is most likely a sub-section of
which CFA Institute Standard of Professional Conduct?
A. Professionalism
B. Duties to Employers
C. Duties to Clients
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Solution -
B is correct.
Standard IV–Duties to Employers includes a sub-section entitled

“Additional Compensation Agreements”.
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Question 22
When can a party, nonmember or firm, most likely claim compliance

with the CFA Institute Code of Ethics and Standards of Professional
Conduct? Once they have:
A. notified the CFA Institute of their claim.

B. verified their claim of compliance with the CFA Institute.
C. ensured that their code and ethics meets the principles of the Code
and Standards.
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Solution -
C is correct.
The Code and Standards apply to individual members of CFA Institute

and candidates in the CFA Program. CFA Institute does encourage firms
to adopt the Code and Standards, however, as part of their code of
ethics. Those who claim compliance should fully understand the
requirements of each of the principles of the Code and Standard.
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Question 23
Lolli Martin, a CFA charterholder, was recently accused in writing of cheating on a
professional accounting exam. She denied cheating and successfully defended
herself against the allegation. As part of her defense and as evidence of her
character, Martin stated that she is a CFA charterholder and upholds the CFA
Institute Code of Ethics and Standards of Professional Conduct. On her next annual
Professional Conduct Statement, Martin does not report this allegation to CFA
Institute. Did Martin most likely violate the CFA Institute Code of Ethics or
Standards of Professional Conduct?
A. Yes, she did not report the allegation on her annual Professional Conduct
Statement.
B. No
C. Yes, she improperly used the CFA Institute Code and Standards to defend herself.
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Solution -
A is correct.
Because Martin should have reported the cheating allegation when
making her annual Professional Conduct Statement. Even though she
successfully defended herself against the charges and the charges were
dropped, she has a responsibility to report the written complaint
involving her integrity. The Code of Ethics requires CFA charterholders to
practice and encourage others to practice in a professional and ethical
manner that will reflect credit on themselves and the profession.
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Professionalism – (ID) Misconduct
Members and Candidates 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.
Question 24
As a condition of his employment with an investment bank, Boom Martel, CFA, was
required to sign an employment contract, including a non-compete clause
restricting him from working for a competitor for three years after leaving the
employer. After one year, Martel quits his job for a comparable position with an
investment bank in a country where non-compete clauses are illegal. Lawyers with
whom he consulted prior to taking the new position determined that the non-
compete clause was a violation of human rights and thus illegal. Did Martel most
likely violate the CFA Institute Code of Ethics and Standards of Professional
Conduct?
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A. No, because the non-compete clause is illegal in the new country of
employment
B. Yes
C. No, because the non-compete clause violates his human rights
52
Solution -
B is correct.
Because by failing to adhere to the non-compete clause he agreed to abide by when

signing his employment contract, Martel shows a lack of professional integrity toward
his employer. This behavior reflects poorly on the good reputation of members and is
a violation of the Code of Ethics, which states that members and candidates must act
with integrity, and Standard I(D)–Misconduct, which states that members and
candidates 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. The Code of Ethics at times requires a member or candidate
to uphold a higher standard than that required by law, rule, or regulation, or in this
case the strict application of the employment agreement.
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Question 25
Julia Girard, CFA, is the chief financial officer at Eureka Computing. Girard is
currently the subject of an inquiry by Eureka’s corporate investigations department.
The inquiry is the result of an anonymous complaint accusing Girard of falsifying
travel expenses for senior management related to a government contract.
According to the CFA Institute Code of Ethics and Standards of Professional
Conduct, it is most appropriate for Girard to disclose the allegations:
A. to CFA Institute when the investigation concludes.
B. to CFA Institute if the allegations are proven correct.
C. on her Professional Conduct Statement.
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Solution -
C is correct.
Because members and candidates must self-disclose on the annual Professional

Conduct Statement all matters that question their professional conduct, such as
involvement in civil litigation or criminal investigations or being the subject of a
written complaint.
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Duties to Employers – IV (C) Responsibilities of Supervisors
Members and Candidates must make reasonable efforts to ensure that anyone subject to their
supervision or authority complies with applicable laws, rules, regulations, and the Code and Standards.
Question 26
Which of the following activities if undertaken by CFA Institute members and/or
candidates would most likely violate the Code and Standards?
A. An institutional portfolio manager takes a group of clients to an expensive
restaurant to discuss portfolio returns over the recently completed quarter
without prior written consent from his employer.
B. An analyst discloses confidential, sensitive information about a client account as
part of an investigation by the CFA Institute Professional Conduct Program.
C. A senior trader does not have safeguards in place to determine whether a junior
trader under their supervision is following the firm’s policies regarding best
execution.
56
Solution -
C is correct.
Because Standard IV(C)–Responsibilities of Supervisors states that members

and candidates must make reasonable efforts to prevent violation of
applicable laws, rules, regulations, and the Code and Standards by anyone
subject to their supervision or authority. Interviewing with a competitor during
lunch or taking clients out to lunch do not necessarily violate any Standard
unless specifically prohibited in company policies.
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Resposibilities as a CFA Institue member or CFA Candidate – VII (B) reference to CFA Institute, CFA
Designation and the CFA Program
When referring to CFA Institute, CFA Institute membership, the CFA designation, or candidacy in the CFA
Program, Members and Candidates must not misrepresent or exaggerate the meaning or implications of
membership in CFA Institute, holding the CFA designation, or candidacy in the CFA Program.
Question 27
Kelly Denz, a new CFA charterholder, had to explain to the marketing
department of her firm that making any claim of superior analytical skills due
to her designation would most likely be a violation of:
A. Standard IV–Duties to Employers.
B. Standard VII–Responsibilities as a CFA Institute Member or CFA Candidate.
C. Standard V–Investment Analysis, Recommendations, and Actions.
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Solution -
B is correct.
Making claims that the CFA designation was proof of superior analytical
skills is a violation of Standard VII(B)–References 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, members and candidates must not misrepresent or exaggerate
the meaning or implication of membership in CFA Institute, holding the
CFA designation, or candidacy in the CFA Program.
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Professionalism – (IB) Independence and Objectivity
Members and Candidates must use reasonable care and judgment to achieve and maintain independence
and objectivity in their professional activities. Members and Candidates 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.
Question 28
Granet Data Corp offered to pay all the expenses of Sumo Fritz, CFA, an equity
analyst who covers the company, to attend the company’s upcoming annual
shareholder meeting. Fritz declined their offer and explained to the company that if
she had accepted their offer she would most likely be in violation of:
A. Standard II–Integrity of Capital Markets
B. Standard III–Conflicts of Interest
C. Standard I–Professionalism
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Solution -
C is correct.
If Fritz were to accept Granet Data Corp’s offer to pay all her expenses
to attend the company’s upcoming annual shareholder meeting she
would be in violation of Standard I(B)–Independence and Objectivity.
Members and candidates must use reasonable care and judgement to
achieve and maintain independence and objectivity in their professional
activities. Members and candidates 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.
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Duties to clients – III (E) Preservation of Confidentiality
Members and Candidates must keep information about current, former, and prospective clients
confidential unless:
a. The information concerns illegal activities on the part of the client;
b. Disclosure is required by law; or
c. The client or prospective client permits disclosure of the information.
Question 29
Standard III(E)–Preservation of Confidentiality of the CFA Institute Standards of
Professional Conduct most likely requires members and candidates to keep
information about current, former, and prospective clients confidential unless:
A. there is a reasonable and adequate basis for not maintaining confidentiality.
B. the information concerns illegal activities.
C. they understand the limitations and risk associated with the disclosure.
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Solution -
B is correct.
Standard III(E)–Preservation of Confidentiality requires members and

candidates to keep information about current, former, and prospective
clients confidential unless the information concerns illegal activities on
part of the client or prospective clients.
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Duties to clients – III (C) Suitability
1. When Members and Candidates are in an advisory relationship with a client, they must:
a. Make a reasonable inquiry into a client’s or prospective client’s investment experience, risk and
return objectives, and financial constraints prior to making any investment recommendation or
taking investment action and must reassess and update this information regularly.
b. Determine that an investment is suitable to the client’s financial situation and consistent with the
client’s written objectives, mandates, and constraints before making an investment
recommendation or taking investment action.
c. Judge the suitability of investments in the context of the client’s total portfolio.
2. When Members and Candidates are responsible for managing a portfolio to a specific mandate,
strategy, or style, they must make only investment recommendations or take only investment actions
that are consistent with the stated objectives and constraints of the portfolio.
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Question 30
Standard III(C)–Suitability of the CFA Institute Standards of Professional

Conduct most likely requires members and candidates to judge the
suitability of an investment in the context of the client’s:
A. total assets.
B. net worth.
C. total portfolio.
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Solution -
C is correct.
Standard III(C)–Suitability of the CFA Institute Standards of Professional

Conduct requires that when members and candidates are in an advisory
relationship with a client, they must judge the suitability of investments
in the context of the client’s total portfolio.
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CFA LEVEL I Guidance for Standards I–VII
Duties to Employers – IV (A) Loyalty
In matters related to their employment, Members and Candidates must act for the benefit of their
employer and not deprive their employer of the advantage of their skills and abilities, divulge confidential
information, or otherwise cause harm to their employer.
Question 31
Anderb Grey, CFA, is a technology analyst at Grand Securities, Inc., and is a leading
authority on Japanese technology companies. Grey’s clients include many leading
Japanese equity managers. While still employed at Grand, Grey makes plans during
weekends to start a new company, MK Consulting. His plans consist of contracting
office space, interviewing potential employees, and purchasing office equipment.
Once he feels ready to launch his new firm, Grey provides Grand with his
resignation notice. After leaving, Grey constructs earnings models of the technology
companies he previously covered, using the knowledge and experience gained
while at Grand. He then contacts former clients by using public sources and
encourages them to become clients of his new firm. Are Grey’s actions in
compliance with the Code and Standards?
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A. No, because the names of former clients, modeling skills and experience gained
by Grey are confidential information of Grand Securities.
B. Yes, assuming he is not in breach of any non-compete agreement signed while at
Grand Securities.
C. No, because he is prohibited from engaging in activities related to starting his
new business while still employed by Grand Securities.
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Solution -
B is correct.
Because Grey’s actions do not violate Standard IV(A)– Duties to

Employers. Grey does not use company time to make arrangements for
his new venture, nor does he misappropriate any information (financial
models or client contacts) from his former employer. All of the actions
performed by Grey are permissible under Standard IV(A).
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Question 32
Lonzy Gravel, CFA, a retired portfolio manager, owns 20,000 shares of a small public
company that he would like to sell because he is worried about the company’s
prospects. He posts messages on several internet bulletin boards. The messages
read, “This stock is going up once the pending patents are released, so now is the
time to buy. The stock is a buy at anything below $3. I have done some close
research on these guys.” According to the Standards of Practice Handbook, Gravel
most likely violated the Standard or Standards associated with:
A. Integrity of Capital Markets, but not Conflicts of Interest.
B. Neither Integrity of Capital Markets nor Conflicts of Interest.
C. Integrity of Capital Markets and Conflicts of Interest.
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Solution -
A is correct.
Because Gravel violated the Integrity of Capital Markets by engaging in a

practice that is likely to artificially inflate trading volume [Standard II(B)].
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Question 33
Rango Devid, CFA, works for Strome, a commercial bank that also has a sizeable sell side
research division. Devid is presenting financing solutions to a potential business client, Valco
Corp. As part of his presentation, Devid mentions that Strome will initiate research coverage
on Valco. Is Devid’s arrangement most likely appropriate with regards to the CFA Standards?
A. No, because Devid cannot offer to provide research coverage on a company if they
become a corporate finance client.
B. No, because Strome cannot provide research coverage on a corporate finance client as
this constitutes a violation of research independence.
C. Yes.
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Solution -
C is correct.
Because under Standard I(B) members and candidates must protect

their independence and objectivity. Agreeing to provide objective
research coverage of a company does not constitute a violation of this
standard provided the analyst writing the report is free to come up with
their own independent conclusion. Devid can agree to provide research
coverage but cannot commit Strome’s research department to providing
a favorable recommendation.
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Professionalism – (IA) Knowledge of the law
Members and Candidates must understand and comply with all applicable laws, rules, and regulations
(including the CFA Institute Code of Ethics and Standards of Professional Conduct) of any government,
regulatory organization, licensing agency, or professional association governing their professional
activities. In the event of conflict, Members and Candidates must comply with the more strict law, rule, or
regulation. Members and Candidates must not knowingly participate or assist in and must dissociate
from any violation of such laws, rules, or regulations.
Question 34
Roberts Nelson, CFA, is a Portfolio Manager at MAX Securities. Nelson has
reasonable grounds to believe his colleague, Kialo Moto, a CFA Level II Candidate, is
engaged in unethical trading activities that may also be in violation of local
securities laws. Nelson is not Moto’s supervisor, and her activities do not impact
Nelson or any of the portfolios for which he is responsible. Based on the Code and
Standards, the recommended course of action is for Nelson to:
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A. report Kialo Moto to MAX’s trading supervisor or compliance department.
B. report Kialo Moto to the appropriate governmental or regulatory organization.
C. not take any action because he is not directly involved.
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Solution -
A is correct.
Because under Standard I(A) in situations where a member or candidate

is aware of employer engagement in unethical or illegal activity, it is
recommended that they attempt to stop the behavior by bringing it to
the attention through a supervisor or the firm’s compliance department.
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investment must not act or cause others to act on the information.
> Information that is ambiguous as to its likely effect on price may not be considered material. > Under
the so-called mosaic theory, reaching an investment conclusion through perceptive analysis of public
information combined with non-material non public information is not a violation of the Standard.
Question 35
According to the CFA Institute Code of Ethics and Standards of Professional
Conduct, trading on material nonpublic information is least likely to be prevented
by establishing:
A. selective disclosure.
B. personal trading limitations.
C. firewalls.
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Solution -
A is correct
As selective disclosure occurs when companies discriminate in making

material nonpublic information public. Corporations that disclose
information on a limited basis create the potential for insider-trading
violations. Standard II(A).
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Question 36
During an on-site company visit, Hong James, CFA, accidentally overheard the Chief
Executive Officer (CEO) of Rojer, Inc., discussing the company’s tender offer to
purchase United Enterprises, a retailer of Rojer products. According to the CFA
Institute Standards of Professional Conduct, James most likely cannot use the
information because:
A. it was overheard and might be considered unreliable.
B. she does not have a reasonable and adequate basis for taking investment action.
C. it relates to a tender offer.
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Solution -
C is correct.
Because trading on the information is restricted as it relates to a tender

offer; it is clearly material, nonpublic information [Standard II(A)].
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Conflict of Interest – VI (A) Disclosure of conflict
Members and Candidates 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. Members and Candidates must ensure that such disclosures are
prominent, are delivered in plain language, and communicate the relevant information effectively.
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Question 37
Sark William, CFA, is the owner and sole employee of two companies, a public
relations firm and a financial research firm. The public relations firm entered into a
contract with Robin Enterprises to provide public relations services, with William
receiving 40,000 shares of Robin stock in payment for his services. Over the next 10
days, the public relations firm issued several press releases that discussed Robin’s
excellent growth prospects. William, through his financial research firm, also
published a research report recommending Robin stock as a “buy.” According to the
CFA Institute Standards of Professional Conduct, William is most likely required to
disclose his ownership of Robin stock in the:
A. research report only.
B. both the press release and the research report.
C. press releases only.
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Solution -
B is correct.
Because members should disclose all matters that reasonably could be

expected to impair the member’s objectivity [Standard I(B), Standard
VI(A)].
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Question 38
Davis Berger, CFA, a portfolio manager for Ground Investments, plans to manage
the portfolios of several family members in exchange for a percentage of each
portfolio’s profits. As his family members have extensive portfolios requiring
substantial attention, they have requested that Berger provide the services outside
his employment with Ground. Berger notifies his employer in writing of his
prospective outside employment. Two weeks later, Berger begins managing the
family members’ portfolios. By managing these portfolios, which of the following
CFA Institute Standards of Professional Conduct has Berger violated?
A. Both Additional Compensation and Conflicts of Interest
B. Additional Compensation
C. Conflicts of Interest
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Solution -
A is correct.
Because members should disclose all potential conflicts of interest, the

substantial time involved in managing family accounts, and when
engaging in independent practice for compensation should not render
services until receiving written consent from all parties [Standard IV(B),
Standard VI(A)].
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Duties to Employers – IV (C) Responsibilities of Supervisors
Members and Candidates must make reasonable efforts to ensure that anyone subject to their
supervision or authority complies with applicable laws, rules, regulations, and the Code and Standards.
Question 39
Rey Noris, CFA, is the CIO for Rose Trust (RT), an investment advisor. Noris recently
assigned one of his portfolio managers, Tom Tasman, to manage several accounts
that primarily invest in thinly traded micro-cap stocks. Noris soon notices that
Tasman places many stock trades for these accounts on the last day of the month,
toward the market’s close. Noris finds this trading activity unusual and speaks to
Tasman who explains that the trading activity was completed at the client’s
request. Noris does not investigate further. Six months later, regulatory authorities
sanction RT for manipulating micro-cap stock prices at month end in order to boost
account values. Did Noris violate any CFA Institute Standards of Professional
Conduct?
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A. Yes, because he failed to reasonably supervise Tasman.
B. Yes, because he did not report his findings to regulatory authorities.
C. No.
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Solution -
A is correct.
Because the CFA Institute Standard on Responsibilities of Supervisors,

Standard IV(C), requires members/candidates to take steps to detect
and prevent violations of laws, rules, and regulations. Noris failed in his
supervisory role when he accepted Tasman’s explanation of the unusual
trading activity. Noris should have reviewed the client’s goals and
objectives and records to see if they in fact requested month-end
trading. Regardless of the explanation provided by Tasman, Noris should
have investigated further.
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Question 40
Boom Martin, CFA, who owns a research and consulting company, is an
independent board member of a leading Steel manufacturer in a small local market.
Because of Martin’s expertise in the Steel industry, a foreign Steel manufacturer
looking to enter the local market has hired him to undertake a feasibility study.
Under what circumstances can Martin most likely undertake the assignment
without violating the CFA Institute Code of Ethics and Standards of Professional
Conduct? If he:
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A. receives written permission from the local company.
B. signs confidentiality agreements with both companies.
C. makes full disclosure to both companies.
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Solution -
C is correct.
Because making full and fair disclosure of all matters that could reasonably be
expected to impair one’s independence and objectivity or interfere with
respective duties to one’s clients is required by Standard VI(A)–Disclosure of
Conflicts of the CFA Institute Code of Ethics and Standards of Professional
Conduct.
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Duties to clients – III (B) Fair Dealing
Members and Candidates must deal fairly and objectively with all clients when providing investment
analysis, making investment recommendations, taking investment action, or engaging in other
professional activities.
Question 41
Smith, a research analyst with a brokerage firm, decides to change his
recommendation for the common stock of Green Company, Inc., from a “buy” to a
“sell.” He mails this change in investment advice to all the firm’s clients on
Wednesday. The day after the mailing, a client calls with a buy order for 500 shares
of Green Company. In this circumstance, Smith should:
A. Accept the order.
B. Advise the customer of the change in recommendation before accepting the
order.
C. Not accept the order because it is contrary to the firm’s recommendation.
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Solution -
B is correct.
This question involves Standard III(B)—Fair Dealing. Smith disseminated a change in the stock
recommendation to his clients but then received a request contrary to that recommendation
from a client who probably had not yet received the recommendation. Prior to executing the
order, Smith should take additional steps to ensure that the customer has received the change
of recommendation.
Answer A is incorrect because the client placed the order prior to receiving the
recommendation and, therefore, does not have the benefit of Smith’s most recent
recommendation.
Answer C is also incorrect; simply because the client request is contrary to the firm’s
recommendation does not mean a member can override a direct request by a client. After
Smith contacts the client to ensure that the client has received the changed recommendation,
if the client still wants to place a buy order for the shares, Smith is obligated to comply with
the client’s directive.
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Question 42
Jamison is a junior research analyst with Howard & Howard, a brokerage and
investment banking firm. Howard & Howard’s mergers and acquisitions department
has represented the Britland Company in all of its acquisitions for the past 20 years.
Two of Howard & Howard’s senior officers are directors of various Britland
subsidiaries. Jamison has been asked to write a research report on Britland. What is
the best course of action for her to follow?
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A. Jamison may write the report but must refrain from expressing any opinions
because of the special relationships between the two companies.
B. Jamison should not write the report because the two Howard & Howard officers
serve as directors for subsidiaries of Britland.
C. Jamison may write the report if she discloses the special relationships with the
company in the report.
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Solution -
C is correct.
This question involves Standard VI(A)—Disclosure of Conflicts. The question
establishes a conflict of interest in which an analyst, Jamison, is asked to write a
research report on a company that is a client of the analyst’s employer. In addition,
two directors of the company are senior officers of Jamison’s employer. Both facts
establish that there are conflicts of interest that must be disclosed by Jamison in her
research report.
Answer B is incorrect because an analyst is not prevented from writing a report
simply because of the special relationship the analyst’s employer has with the
company as long as that relationship is disclosed.
Answer A is incorrect because whether or not Jamison expresses any opinions in the
report is irrelevant to her duty to disclose a conflict of interest. Not expressing
opinions does not relieve the analyst of the responsibility to disclose the special
relationships between the two companies.
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Investment Analysis, Recommendations and Actions – V (A) Diligence and Reasonable basis
1. Exercise diligence, independence, and thoroughness in analyzing investments, making investment
recommendations, and taking investment actions.
2. Have a reasonable and adequate basis, supported by appropriate research and investigation, for any
investment analysis, recommendation, or action.
Question 43
Willier is the research analyst responsible for following Company X. All the
information he has accumulated and documented suggests that the outlook for the
company’s new products is poor, so the stock should be rated a weak “hold.”
During lunch, however, Willier overhears a financial analyst from another firm
whom he respects offer opinions that conflict with Willier’s forecasts and
expectations. Upon returning to his office, Willier releases a strong “buy”
recommendation to the public. Willier:
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A. Violated the Standards by failing to distinguish between facts and opinions in his
recommendation.
B. Violated the Standards because he did not have a reasonable and adequate basis
for his recommendation.
C. Was in full compliance with the Standards.
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Solution -
B is correct
This question relates to Standard V(A)—Diligence and Reasonable Basis. The opinion
of another financial analyst is not an adequate basis for Willier’s action in changing
the recommendation.
Answer C is thus incorrect. So is answer A because, although it is true that members
and candidates must distinguish between facts and opinions in recommendations, the
question does not illustrate a violation of that nature. If the opinion overheard by
Willier had sparked him to conduct additional research and investigation that justified
a change of opinion, then a changed recommendation would be appropriate.
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Question 44
An investment management firm has been hired by ETV Corporation to work on an
additional public offering for the company. The firm’s brokerage unit now has a
“sell” recommendation on ETV, but the head of the investment banking department
has asked the head of the brokerage unit to change the recommendation from
“sell” to “buy.” According to the Standards, the head of the brokerage unit would
be permitted to:
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A. Increase the recommendation by no more than one increment (in this case, to a
“hold” recommendation).
B. Place the company on a restricted list and give only factual information about the
company.
C. Assign a new analyst to decide if the stock deserves a higher rating.
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Solution -
B is correct.
This question relates to Standard I(B)— Independence and Objectivity. When asked to
change a recommendation on a company stock to gain business for the firm, the head
of the brokerage unit must refuse in order to maintain his independence and
objectivity in making recommendations. He must not yield to pressure by the firm’s
investment banking department. To avoid the appearance of a conflict of interest, the
firm should discontinue issuing recommendations about the company.
Answer A is incorrect; changing the recommendation in any manner that is contrary
to the analyst’s opinion violates the duty to maintain independence and objectivity.
Answer C is incorrect because merely assigning a new analyst to decide whether the
stock deserves a higher rating will not address the conflict of interest.
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VII (B) reference to CFA Institute, CFA Designation and the CFA Program
Question 45
Albert and Tye, who recently started their own investment advisory business, have
registered to take the Level III CFA examination. Albert’s business card reads, “Judy
Albert, CFA Level II.” Tye has not put anything about the CFA designation on his
business card, but promotional material that he designed for the business describes
the CFA requirements and indicates that Tye participates in the CFA Program and
has completed Levels I and II. According to the Standards:
A. Albert has violated the Standards, but Tye has not.
B. Tye has violated the Standards, but Albert has not.
C. Both Albert and Tye have violated the Standards.
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Solution -
A is correct.
Standard VII(B)—Reference to CFA Institute, the CFA Designation, and the CFA
Program is the subject of this question. The reference on Albert’s business
card implies that there is a “CFA Level II” designation; Tye merely indicates in
promotional material that he is participating in the CFA Program and has
completed Levels I and II. Candidates may not imply that there is some sort of
partial designation earned after passing a level of the CFA exam. Therefore,
Albert has violated Standard VII(B). Candidates may communicate that they
are participating in the CFA Program, however, and may state the levels that
they have completed. Therefore, Tye has not violated Standard VII(B).
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Prospective Clients
investment process.
recommendations, or actions and include those factors in communications with clients and
recommendations.
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Question 46
Scott works for a regional brokerage firm. He estimates that Walkton Industries will
increase its dividend by US$1.50 a share during the next year. He realizes that this
increase is contingent on pending legislation that would, if enacted, give Walkton a
substantial tax break. The US representative for Walkton’s home district has told
Scott that, although she is lobbying hard for the bill and prospects for its passage
are favourable, concern of the US Congress over the federal deficit could cause the
tax bill to be voted down. Walkton Industries has not made any statements about a
change in dividend policy. Scott writes in his research report, “We expect Walkton’s
stock price to rise by at least US$8.00 a share by the end of the year because the
dividend will increase by US$1.50 a share. Investors buying the stock at the current
time should expect to realize a total return of at least 15% on the stock.” According
to the Standards:
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A. Scott violated the Standards because he used material inside information.
B. Scott violated the Standards because he failed to separate opinion from fact.
C. Scott violated the Standards by basing his research on uncertain predictions of
future government action.
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Solution -
B is correct.
This question relates to Standard V(B)— Communication with Clients and Prospective
Clients. Scott has issued a research report stating that he expects the price of Walkton
Industries stock to rise by US$8 a share “because the dividend will increase” by
US$1.50 per share. He has made this statement knowing that the dividend will
increase only if Congress enacts certain legislation, an uncertain prospect. By stating
that the dividend will increase, Scott failed to separate fact from opinion. The
information regarding passage of legislation is not material non public information
because it is conjecture, and the question does not state whether the US
representative gave Scott her opinion on the passage of the legislation in confidence.
She could have been offering this opinion to anyone who asked. Therefore, statement
A is incorrect. It may be acceptable to base a recommendation, in part, on an
expectation of future events, even though they may be uncertain. Therefore, answer
C is incorrect.
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Question 47
Jurgen is a portfolio manager. One of her firm’s clients has told Jurgen that he will
compensate her beyond the compensation provided by her firm on the basis of the
capital appreciation of his portfolio each year. Jurgen should:
A. Turn down the additional compensation because it will result in conflicts with the
interests of other clients’ accounts.
B. Turn down the additional compensation because it will create undue pressure on
her to achieve strong short- term performance.
C. Obtain permission from her employer prior to accepting the compensation
arrangement.
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Solution -
C is correct.
This question involves Standard IV(B)—Additional Compensation Arrangements. The
arrangement described in the question— whereby Jurgen would be compensated
beyond the compensation provided by her firm, on the basis of an account’s
performance—is not a violation of the Standards as long as Jurgen discloses the
arrangement in writing to her employer and obtains permission from her employer
prior to entering into the arrangement.
Answers A and B are incorrect; although the private compensation arrangement
could conflict with the interests of other clients and lead to short- term performance
pressures, members and candidates may enter into such agreements as long as they
have disclosed the arrangements to their employer and obtained permission for the
arrangement from their employer.
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Duties to clients – III (A) Loyalty, Prudence and Care
Members and Candidates have a duty of loyalty to their clients and must act with reasonable care and
exercise prudent judgment. Members and Candidates must act for the benefit of their clients and place
their clients’ interests before their employer’s or their own interests.
Question 48
One of the discretionary accounts managed by Farnsworth is the Jones Corporation employee profit-
sharing plan. Jones, the company president, recently asked Farnsworth to vote the shares in the profit-
sharing plan in favor of the slate of directors nominated by Jones Corporation and against the directors
sponsored by a dissident stockholder group. Farnsworth does not want to lose this account because he
directs all the account’s trades to a brokerage firm that provides Farnsworth with useful information
about tax- free investments. Although this information is not of value in managing the Jones
Corporation account, it does help in managing several other accounts. The brokerage firm providing
this information also offers the lowest commissions for trades and provides best execution.
Farnsworth investigates the director issue, concludes that the management- nominated slate is better
for the long- run performance of the company than the dissident group’s slate, and votes accordingly.
Farnsworth:
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A. Violated the Standards in voting the shares in the manner requested by Jones but
not in directing trades to the brokerage firm.
B. Did not violate the Standards in voting the shares in the manner requested by
Jones or in directing trades to the brokerage firm.
C. Violated the Standards in directing trades to the brokerage firm but not in voting
the shares as requested by Jones.
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Solution -
B is correct.
This question relates to Standard III(A)—Loyalty, Prudence, and Care—specifically, a
member’s or candidate’s responsibility for voting proxies and the use of client
brokerage. According to the facts stated in the question, Farnsworth did not violate
Standard III(A). Although the company president asked Farnsworth to vote the shares
of the Jones Corporation profit sharing plan a certain way, Farnsworth investigated
the issue and concluded, independently, the best way to vote. Therefore, even
though his decision coincided with the wishes of the company president, Farnsworth
is not in violation of his responsibility to be loyal and to provide care to his clients. In
this case, the participants and the beneficiaries of the profit- sharing plan are the
clients, not the company’s management. Had Farnsworth not investigated the issue
or had he yielded to the president’s wishes and voted for a slate of directors that he
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had determined was not in the best interest of the company, Farnsworth would have
violated his responsibilities to the beneficiaries of the plan. In addition, because the
brokerage firm provides the lowest commissions and best execution for securities
transactions, Farnsworth has met his obligations to the client in using this brokerage
firm. It does not matter that the brokerage firm also provides research information
that is not useful for the account generating the commission because Farnsworth is
not paying extra money of the client’s for that information.
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b. Determine that an investment is suitable to the client’s financial situation and consistent with
the client’s written objectives, mandates, and constraints before making an investment
strategy, or style, they must make only investment recommendations or take only investment
actions that are consistent with the stated objectives and constraints of the portfolio.
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Question 49
Brown works for an investment counselling firm. Green, a new client of the firm, is
meeting with Brown for the first time. Green used another counselling firm for
financial advice for years, but she has switched her account to Brown’s firm. After
spending a few minutes getting acquainted, Brown explains to Green that she has
discovered a highly undervalued stock that offers large potential gains. She
recommends that Green purchase the stock. Brown has committed a violation of
the Standards. What should she have done differently?
A. Brown should have determined Green’s needs, objectives, and tolerance for risk
before making a recommendation of any type of security.
B. Brown should have thoroughly explained the characteristics of the company to
Green, including the characteristics of the industry in which the company
operates.
C. Brown should have explained her qualifications, including her education, training,
and experience and the meaning of the CFA designation.
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Solution -
A is correct.
In this question, Brown is providing investment recommendations before making
inquiries about the client’s financial situation, investment experience, or investment
objectives. Brown is thus violating Standard III(C)—Suitability. Answers B and C
provide examples of information members and candidates should discuss with their
clients at the outset of the relationship, but these answers do not constitute a
complete list of those factors. Answer A is the best answer.
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Professionalism – (IC) Misrepresentation
Members and Candidates must not knowingly make any misrepresentations relating to investment
analysis, recommendations, actions, or other professional activities.
Question 50
Grey recommends the purchase of a mutual fund that invests solely in long term US
Treasury bonds. He makes the following statements to his clients:
I. “The payment of the bonds is guaranteed by the US government; therefore, the
default risk of the bonds is virtually zero.”
II. “If you invest in the mutual fund, you will earn a 10% rate of return each year
for the next several years based on historical performance of the market.”
Did Grey’s statements violate the CFA Institute Code and Standards?
A. Neither statement violated the Code and Standards.
B. Only statement I violated the Code and Standards.
C. Only statement II violated the Code and Standards.
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Solution -
C is correct.
This question involves Standard I(C)— Misrepresentation. Statement I is a factual
statement that discloses to clients and prospects accurate information about the
terms of the investment instrument. Statement II, which guarantees a specific rate of
return for a mutual fund, is an opinion stated as a fact and, therefore, violates
Standard I(C). If statement II were rephrased to include a qualifying statement, such
as “in my opinion, investors may earn . . . ,” it would not be in violation of the
Standards.
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Question 51
Ward is scheduled to visit the corporate headquarters of Evans Industries. Ward
expects to use the information he obtains there to complete his research report on
Evans stock. Ward learns that Evans plans to pay all of Ward’s expenses for the trip,
including costs of meals, hotel room, and air transportation. Which of the following
actions would be the best course for Ward to take under the Code and Standards?
A. Accept the expense-paid trip and write an objective report.
B. Pay for all travel expenses, including costs of meals and incidental items.
C. Accept the expense-paid trip but disclose the value of the services accepted in the
report.
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Solution -
B is correct.
The best course of action under Standard I(B)— Independence and Objectivity is to
avoid a conflict of interest whenever possible. Therefore, for Ward to pay for all his
expenses is the correct answer. Answer C details a course of action in which the
conflict would be disclosed, but the solution is not as appropriate as avoiding the
conflict of interest. Answer A would not be the best course because it would not
remove the appearance of a conflict of interest; even though the report would not be
affected by the reimbursement of expenses, it could appear to be.
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Question 52
Smith is a financial analyst with XYZ Brokerage Firm. She is preparing a purchase
recommendation on JNI Corporation. Which of the following situations is most
likely to represent a conflict of interest for Smith that would have to be disclosed?
A. Smith frequently purchases items produced by JNI.
B. XYZ holds for its own account a substantial common stock position in JNI.
C. Smith’s brother- in- law is a supplier to JNI.
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Solution -
B is correct.
This question involves Standard VI(A)—Disclosure of Conflicts—specifically, the
holdings of an analyst’s employer in company stock. Answers A and C do not describe
conflicts of interest that Smith would have to disclose. Answer A describes the use of
a firm’s products, which would not be a required disclosure. In answer C, the
relationship between the analyst and the company through a relative is so tangential
that it does not create a conflict of interest necessitating disclosure.
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Conflict of Interest – VI (B) Priority of Transaction
Investment transactions for clients and employers must have priority over investment transactions in
which a Member or Candidate is the beneficial owner.
Question 53
Rose, a portfolio manager for a local investment advisory firm, is planning to sell a
portion of his personal investment portfolio to cover the costs of his child’s
academic tuition. Rose wants to sell a portion of his holdings in Household
Products, but his firm recently upgraded the stock to “strong buy.” Which of the
following describes Rose’s options under the Code and Standards?
A. Based on his firm’s “buy” recommendation, Rose cannot sell the shares because
he would be improperly prospering from the inflated recommendation.
B. Rose is free to sell his personal holdings once his firm is properly informed of his
intentions.
C. Rose can sell his personal holdings but only when a client of the firm places an
order to buy shares of Household.
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Solution -
B is correct.
Standard VI(B)—Priority of Transactions does not limit transactions of company
employees that differ from current recommendations as long as the sale does not
disadvantage current clients. Thus, answer A is incorrect. Answer C is incorrect
because the Standard does not require the matching of personal and client trades.
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Question 54
Paper was recently terminated as one of a team of five managers of an equity fund.
The fund had two value- focused managers and terminated one of them to reduce
costs. In a letter sent to prospective employers, Paper presents, with written
permission of the firm, the performance history of the fund to demonstrate his past
success.
A. Paper did not violate the Code and Standards.
B. Paper violated the Code and Standards by claiming the performance of the entire
fund as his own.
C. Paper violated the Code and Standards by including the historical results of his
prior employer.
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Solution -
B is correct.
Paper has violated Standard III(D)—Performance Presentation by not disclosing that
he was part of a team of managers that achieved the results shown. If he had also
included the return of the portion he directly managed, he would not have violated
the standard. Thus, answer A is incorrect. Answer C is incorrect because Paper
received written permission from his prior employer to include the results.
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Responsibilities as a CFA Institute member or CFA Candidate – VII (A) Conduct as Participants in CFA
Institute Programs
Members and Candidates 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 CFA Institute programs.
Question 55
Park is very frustrated after taking her Level II exam. While she was studying for the
exam, to supplement the curriculum provided, she ordered and used study material
from a third- party provider. Park believes the additional material focused her
attention on specific topic areas that were not tested while ignoring other areas.
She posts the following statement on the provider’s discussion board: “I am very
dissatisfied with your firm’s CFA Program Level II material. I found the exam
extremely difficult and myself unprepared for specific questions after using your
product. How could your service provide such limited instructional resources on the
analysis of inventories and taxes when the exam had multiple questions about
them? I will not recommend your products to other candidates.
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A. Park violated the Code and Standards by purchasing third- party review
material.
B. Park violated the Code and Standards by providing her opinion on the
difficulty of the exam.
C. Park violated the Code and Standards by providing specific information on
topics tested on the exam.
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Solution -
C is correct.
Standard VII(A)—Conduct as Members and Candidates in the CFA Program
prohibits providing information to candidates or the public that is considered
confidential to the CFA Program. In revealing that questions related to the
analysis of inventories and analysis of taxes were on the exam, Park has
violated this standard. Answer B is incorrect because the guidance for the
standard explicitly acknowledges that members and candidates are allowed to
offer their opinions about the CFA Program. Answer A is incorrect because
candidates are not prohibited from using outside resources.
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Responsibilities as a CFA Institue member or CFA Candidate – VII (B) reference to CFA Institute, CFA
Designation and the CFA Program
Question 56
Quinn sat for the Level III CFA exam this past weekend. He updates his
resume with the following statement: “In finishing the CFA Program, I
improved my skills related to researching investments and managing
portfolios. I will be eligible for the CFA charter upon completion of the
required work experience.”
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A. Quinn violated the Code and Standards by claiming he improved his skills
through the CFA Program.
B. Quinn violated the Code and Standards by incorrectly stating that he is
eligible for the CFA charter.
C. Quinn did not violate the Code and Standards with his resume update.
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Solution -
B is correct.
According to Standard VII(B)—Reference to CFA Institute, the CFA Designation,
and the CFA Program, Quinn cannot claim to have finished the CFA Program or
be eligible for the CFA charter until he officially learns that he has passed the
Level III exam. Until the results for the most recent exam are released, those
who sat for the exam should continue to refer to themselves as “candidates.”
Thus, answer C is incorrect. Answer A is incorrect because members and
candidates may discuss areas of practice in which they believe the CFA
Program improved their personal skills.
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Investment Analysis, Recommendations and Actions – V (C) Record retention
Members and Candidates must develop and maintain appropriate records to support their investment
analyses, recommendations, actions, and other investment-related communications with clients and
Question 57
Cannan has been working from home on weekends and occasionally saves
correspondence with clients and completed work on her home computer.
Because of worsening market conditions, Cannan is one of several
employees released by her firm. While Cannan is looking for a new job, she
uses the files she saved at home to request letters of recommendation from
former clients. She also provides to prospective clients some of the reports
as examples of her abilities.
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A. Cannan violated the Code and Standards because she did not receive
permission from her former employer to keep or use the files after her
employment ended.
B. Cannan did not violate the Code and Standards because the files were
created and saved on her own time and computer.
C. Cannan violated the Code and Standards because she is prohibited from
saving files on her home computer.
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Solution -
A is correct.
According to Standard V(C)—Record Retention, Cannan needed the
permission of her employer to maintain the files at home after her
employment ended. Without that permission, she should have deleted the
files. All files created as part of a member’s or candidate’s professional activity
are the property of the firm, even those created outside normal work hours.
Thus, answer B is incorrect. Answer C is incorrect because the Code and
Standards do not prohibit using one’s personal computer to complete work for
one’s employer.
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Question 58
Acuity Systems is an investment management firm that adopted the Code and
Standards as part of its policy manual. Gerald Smithson, CFA, has recently added
the stock of Advanced Biochemical Company and Norgood PLC to all his client's
investment portfolios. Shortly afterwards Advanced Biochemical and Norgood
announced a merger that increased the share price of both companies. Smithson
contends he saw the president of Advanced Biochemical dining with the
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chairman of Norgood, but did not overhear their conversation. Smithson
researched both companies extensively and determined that each company was a
good investment. He put in a block trade for shares in each company.
Acuity's policies were not clear in this area as he allocated the shares by starting
with his largest client accounts and working down to the small accounts. Some of
Smithson's clients were very conservative personal trust accounts, others were
pension funds who had aggressive investment objectives. Which standard was NOT
broken?
A. Standard V(A)--Diligence and Reasonable Basis.

B. Standard IV(C)--Responsibilities of Supervisors.
C. Standard III(C)-- Suitability.
139
Solution -
A is correct.
Standard V(A) Diligence and Reasonable Basis was not broken because
Smithson conducted thorough and diligent research. Standard III(C)--
Suitability, Smithson failed to consider the needs of his conservative and
aggressive clients. Standard IV(C)--Responsibilities of Supervisors, Activision
Partners didn't have policies explaining how to allocate shares among clients.
140
Question 59
Boob Brownywell, CFA, works as an investment manager for Mega Capital, a large
multinational brokerage firm. Mega Capital is based in a country whose applicable
law is stricter than the CFA Institute Code and Standards, but does business with
clients in a country whose applicable law is less strict than the Code and
Standards. Brownywell decides to follow the requirements of the Code and
Standards for clients in the less strict country, which is sufficient to also comply
with that less-strict country's local laws. While Brownywell is still employed at
Mega, Lego Associates verbally asks Brownywell to review client portfolios
during evenings and weekends for a fee. Brownywell gets written consent from
his immediate supervisor at Mega to undertake this independent activity for a one-
month trial basis.
Which of the following statements about Brownywell's actions involving Standard I,
Professionalism, and Standard IV(A), Loyalty is most accurate? Brownywell:
141
A. violated both Standard I and Standard IV(A).
B. violated Standard I but did not violate Standard IV(A).
C. did not violate either Standard I or Standard IV(A).
142
Solution -
B is correct.
Brownywell violated Standard I, Professionalism. Jameson must comply with
the strictest requirements among the laws of the country where his firm is
based, the CFA Institute Code and Standards, and the laws of the country
where he is doing business. Because the applicable laws in Mega Capital's
home country are stricter than the Code and Standards, Jameson must
additionally adhere to that more strict law.
143
Question 60
Klaus Gerber, CFA, is a regular contributor to the Internet site WizeGuy. This past
week Gerber has been incorrectly quoted as recommending that investors buy
shares in Bradford, Inc. He is unaware that this message has been placed on the
site as the quote was placed as a prank by an unknown source. This is the third time
this has happened over the past month and each time the stock being mentioned
moved in price according to the buy or sell recommendation. Fritz Fox, CFA,
144
maintains and updates the WizeGuy site and has learned how to determine if the
quotes being attributed to Gerber are actually valid. Several days later, he observes
an investment recommendation, posted on the site, to buy Gresham, Inc. The
investment recommendation is purported to be from Gerber, but Fox actually
knows it to be bogus. He immediately sells 1,000 Gresham short and e-mails
Gerber to inform him of the bogus recommendation. Gerber immediately issues a
rebuttal, and Gresham falls by 14%. Fox's action is:
A. a violation of the Standard concerning fiduciary duties.
B. a violation of the Standard concerning use of material nonpublic information.
C. not in violation of the Code and Standards.
145
Solution -
B is correct.
Even though the information is false, this fact is known only to Fox and is thus
nonpublic information. Since such recommendations have in the past had a significant
affect on the price of the security in question, the information is clearly material. Fox
is in violation of Standard II(A) Material Nonpublic Information.
146
Question 61
Robin Anderson, a CFA Level I candidate, trades cotton contracts for a small
commodity broker. Ander- son convinces a government cotton inspector to issue a
warning that the Texas cotton crop is in danger from insect infestation. The price of
cotton soars. Anderson immediately shorts cotton futures. Once the position is
created, the government inspector issues a second report reversing his original
opinion and cotton prices plummet.
Fedric Cunny, a CFA Level III candidate, would like to generate a tax loss on a
security held in his personal portfolio; however, he believes the security has
significant upside potential. To avoid the wash sale provisions of the income tax
147
code, Cunny sells the security and simultaneously creates a synthetic long position
using derivatives.
With regard to Standard II(B) Sarket Manipulation, which of the following
statements concerning Ander- son's and Cunny's conduct is CORRECT?
A. Anderson is in violation of Standard II(B), but Cunny is not in violation.
B. Neither Anderson nor Cunny is in violation of Standard II(B).
C. Both Anderson and Cunny are in violation of Standard II(B).
148
Solution -
A is correct.
Anderson is in violation of Standard II(B) Sarket Manipulation by creating a scheme
that caused others to trade on false information. Cunny is not in violation of Standard
II(B). The Standard does not prohibit transactions conducted for tax purposes.
149
150
Question 62
Katherine Abbott, a CFA charterholder, is preparing a research report on Gonzalez
Company for her employer, Capital Asset Management. Stiven Cook, president of
Boswell, invites Abbott and several other analysts to visit his company and offers
to pay her transportation and lodging. Abbott declines Cook 's offer but, while visiting
the company, accepts a gift from Cook valued at $75. Abbott fails to disclose the gift
to her supervisor at Capital when she returns. In the course of the company visit,
Abbott overhears a conversation between Cook and his chief financial officer that the
company's earnings per share (EPS) are expected to be $1.10 for the next quarter.
Abbott was surprised that this EPS is substantially above her initial earnings estimate
of $0.70 per share. Without further investigation, Abbott decides to include the
$1.10 EPS in her research report on Boswell. Using the high EPS positively affects her
recommendation of Boswell.
151
Which of the following statements about whether Abbott violated Standard V(A),
Diligence and Reasonable Basis and Standard I(B), Independence and Objectivity is
CORRECT? Abbott:
A. did not violate Standard V(A) but she violated Standard I(B).
B. violated both Standard V(A) and Standard I(B).
C. violated Standard V(A) but she did not violate Standard I(B).
152
Solution -
C is correct.
Abbott violated Standard V(A), Diligence and Reasonable Basis, because she did not
have a reasonable and adequate basis to support the $1.10 EPS without further
investigation. By including the $1.10 EPS in her report, she did not exercise diligence
and thoroughness to ensure that any research report finding is accurate. If Abbott
suspects that any information in a source is not accurate, she should refrain from
relying on that information. Abbott did not violate Standard I(B), Independence
and Objectivity, because the gift from Cook was merely a token item.
153
Question 63
An analyst meets with a new client. During the meeting, the analyst sees that the new
client's portfolio is heavily invested in one over-the-counter stock. The analyst has
been following the stock and thinks it will perform well in the long run. The analyst
arranges through a brokerage firm to simultaneously sell a large number of shares of
the stock via a series of cross trades from the new client's portfolio to various existing
clients. He arranges the trades to be executed at a price that approximates the
current market price. This action is:
A. not in violation of the Standards.
B. a violation of Standard III(A), Loyalty, Prudence, and Care.
C. a violation of Standard III(B), Fair Dealing.
154
Solution -
A is correct.
There is no violation. It is in the best interest of the client to be diversified and selling
via a series of cross trades will likely reduce price impact costs when compared to
selling directly into the market. The analyst appears to have reasonable basis for
putting the securities in the accounts of other clients.
155
Question 64
Moore West is a CFA charterholder and trust officer for REO Trust Company. Soon
after beginning work for REO, West finds that REO has been conducting all its
securities transactions through her brother who is a registered representative.
West's brother charges REO commissions that are equal to the lowest available from
another broker. West's brother tells her that if she continues doing business with
him, he will give her a substantial discount on all personal transactions she
conducts through him. West:
A. must inform her employer of the arrangement because it provides her with
additional compensation.
B. must inform her employer of the arrangement because she is doing business with
a member of her immediate family.
C. does not need to inform her employer of the arrangement because the
commissions her brother charges the firm are the lowest possible.
156
Solution -
A is correct.
Members are required to disclose to their employer in writing all monetary
compensation or other benefit they receive in addition to the employer's
compensation. The discounting of West's commissions is a benefit that must be
disclosed.
157
Question 65
Maria Kalchin, CFA, is a representative for Thiel Financial Network. Kalchin received
a phone call at home from William Kind, a junior executive at Westtown
Development Company, asking whether Kalchin had heard that Westtown had
just reached an agreement to acquire a major shopping mall chain at a very
favorable price. (Kalchin had not heard this news, and Kalchin was able to confirm
that the information had not yet been made public.) Kind requested that Kalchin
acquire 10,000 shares of Westtown for Kind's personal account. Kalchin should:
158
A. not acquire the shares until he has contacted Westtown's management and
encouraged them to publicly announce the merger discussion.
B. not acquire the shares.
C. not acquire the shares until the information is made public.
159
Solution -
C is correct.
Standard II(A) prohibits members from taking investment action if they possess
material nonpublic information. Kind has a duty to keep information confidential
that he acquired in the course of his duties at Westtown. The information is clearly
material, so Kalchin is not permitted to trade on it. Kalchin should make
reasonable efforts to achieve public dissemination of the information by
contacting management and encouraging them to make the information public.
Kalchin may not trade on the information until it is made public.
160
Duties to Employers – IV (A) Loyalty
In matters related to their employment, Members and Candidates must act for the benefit of their
employer and not deprive their employer of the advantage of their skills and abilities, divulge confidential
information, or otherwise cause harm to their employer.
Investment Analysis, Recommendations and Actions – V (C) Record retention
Members and Candidates must develop and maintain appropriate records to support their investment
analyses, recommendations, actions, and other investment-related communications with clients and
Question 66
Hall Bergeron recently joined Bloomington Investments as a research analyst. After
spending an afternoon looking through the research team's archives, Bergeron
is not sure Bloomington maintains the records that support the team's
analysis and recommendations for the minimum 7-year period called for by
Standard V(C), Record Retention. What is Bergeron's most appropriate course of
action?
161
A. Decline to participate in any new research until she can verify that the firm is in
compliance with the Standard.
B. Review the firm's record retention procedures with her supervisor or
compliance officer to ensure that they comply with the Standard, or suggest ways
to bring them into compliance.
C. Keep her own copies of the relevant records and maintain them at home for a
minimum 7-year holding period.
162
Solution -
B is correct.
Standard V(C), Record Retention requires that members maintain all records
supporting analysis, recommendations, actions, and all other investment related
communications with clients and prospects. The recommended procedures for
compliance with Standard V(C) state that the record-keeping requirement is generally
the firm's responsibility. These records are the property of the firm, so
Bergeron keeping her own copies at home could potentially violate Standard IV(A),
Loyalty. Bergeron's best course of action is to review the firm's procedures with her
supervisor and recommend any improvements that are necessary to bring them into
compliance with Standard V(C).
163
Question 67
Alonzo Myers manages accounts at GRTY Securities. Jerry Reed, one of his
clients, e-mailed Myers to buy 300 shares in the IPO of JJKS Corp’s stock. Few
days later, despite being a hot issue, Myers succeeded prorating 500 shares of
JJKS Corp. for his clients. After purchasing 500 shares for his clients and 300 shares
for Reed as per request, he purchased remaining 200 shares for his wife. Myers:
A. did not violate the standards by purchasing 200 shares for his wife and 300 shares
for Reed
B. violated the standards by purchasing 200 shares for his wife and only 300 shares
for Reed.
C. violated the standards by purchasing 200 shares for his wife but is in
compliance for purchasing 300 shares for Reed as per his request.
164
Solution -
B is correct.
In context of IPOs member or candidates are prohibited from purchasing
securities for their own benefit and their duty of loyalty and fairness to clients
cannot be overridden by client consent to patently unfair allocation procedure. If
the IPO is suitable for clients and is a hot issue he should allocate shares to all his
clients on a pro-rata basis.
165
1. Members and Candidates must keep information about current, former, and prospective clients
confidential unless;
2. The information concerns illegal activities on the part of the client;
3. Disclosure is required by law; or
4. The client or prospective client permits disclosure of the information.
Question 68
While at a bar in the financial district after work, Ellen Miffitt, CFA, overhears
several employees of a competitor discuss how they will manipulate down the price
of a thinly traded micro-cap stock's price over the next few days. Miffitt's clients have
large positions of this stock, so when she arrives at work the next day, she
immediately sells all of these holdings. Because she had determined the micro-cap
stock was suitable for all of her accounts at its previously higher price, Miffitt
buys back her client's original exposure at the end of the week at the new, lower
price. Which CFA Institute Standards of Professional Conduct did Miffitt least
likely violate?
166
A. Material Nonpublic Information
B. Preservation of Confidentiality
C. Market Manipulation
167
Solution -
B is correct.
Miffitt has not violated Standard III (E)–Preservation of Confidentiality, which
involves information about former, current, and prospective clients.
168
1. Members and Candidates must keep information about current, former, and prospective clients
confidential unless;
2. The information concerns illegal activities on the part of the client;
3. Disclosure is required by law; or
4. The client or prospective client permits disclosure of the information.
Question 69
Edward Li is an analyst at an equity management firm in the U.S. During a meeting
with one of his clients, Vincent Yan, Li discovered that Yan has a surplus of $30,000
to invest in a diversified mutual fund. A few days later, Li attended a
conference of reputable financial analysts and portfolio managers. There he met
Wilbert Ho, the manager of one of the area’s best performing mutual funds. In an
attempt to help his client, Li told Ho to contact Yan, one of his clients who had
$30,000 cash, and offer him performance details of his mutual fund. By revealing
information about his client, Li has most likely:
169
A. violated Standard III (E)—Preservation of Confidentiality.
B. not violated Standard III (E)—Preservation of Confidentiality because the
information was not confidential.
C. not violated Standard III (E)—Preservation of Confidentiality because Li’s intent
was to help his client as is stipulated by his duty of loyalty to the client.
170
Solution -
A is correct.
Even though his intentions were good, Li has violated Standard lll (E) by revealing
confidential information about his client.
171
Question 70
Casey Hart is a fixed-income analyst at Golden Gust Investments (GGIN), an asset
management firm in Indianapolis, USA. Hart is planning to leave the firm to start
her own advisory business with an old friend and an entrepreneur. To ensure that
she does not engage in any unethical or controversial practices, Hart refrains from
soliciting clients while employed at GGIN. In addition, she does not take
documents or other confidential information from the firm. Hart plans to copy
and take with her only her own recommended list of securities and her personal
marketing presentations containing her performance record. With regards to
Standard IV—Duties to Employers, Hart has most likely:
A. violated her duty of loyalty to the firm.
B. not violated her duty of loyalty since she plans to take only personal information
with her.
C. not violated her duty of loyalty since her work and experience gained at
GGIN is her property and not the firm’s.
172
Solution -
A is correct.
Hart has violated her duty of loyalty to the firm. She made the recommendations and
prepared the presentations using GGIN’s resources while being employed at the
firm. Hence, such documents are the property of GGIN and Hart will be in violation
of her duty of loyalty to the firm if she plans to take them with her without
permission.
173
Question 71
A central bank fines a commercial bank it supervises for not following
statutory regulations regarding nonperforming loan provisions on three large
loans as a result of the bank's loan provisioning policy. Louis Marie Buffet,
CFA, sits on the board of directors of the commercial bank as a non-executive
director, representing minority shareholders. He also chairs the bank's internal
audit committee that determines the loan provisioning policy of the bank.
Mercy Gatabaki, CFA, is the bank's external auditor and follows international
auditing standards whereby she tests the loan portfolio by randomly selecting
loans to check for compliance in all aspects of central bank regulations. Which
charterholder is most likely in violation of the Code and Standards?
A. Gatabaki
B. Buffet
C. Both
174
Solution -
B is correct.
Buffet sat on the audit committee that determined the bank's provisioning
policies that were contrary to the statutory regulations of the central bank. As
a result, he most likely violated Standard I–Professionalism by not abiding by
regulations of a regulatory body. Gatabaki did not violate Standard I -
Professionalism because it is not apparent she knowingly facilitated the incorrect
provisioning policy.
175
b. Determine that an investment is suitable to the client’s financial situation and consistent with the
client’s written objectives, mandates, and constraints before making an investment
strategy, or style, they must make only investment recommendations or take only investment
actions that are consistent with the stated objectives and constraints of the portfolio.
176
Question 72
Noor Mawar, CFA, manages a trust fund with the beneficiary being an orphaned 18-
year-old student. The investment policy dictates that trust assets are expected to
provide the student with a stable low-risk source of income until she reaches the
age of 30 years. Based on information from an Internet blog, the student asks
Mawar to invest in a new business venture that she expects will provide high
returns over the next five years. Mawar ignores the request, instead securing
conservative investments to provide sufficient income. Did Mawar most likely
violate the CFA Institute Code of Ethics and Standards of Professional Conduct?
A. Yes.
B. No, because the client’s objectives were met.
C. No, because the investment time frame does not match the investment horizon.
177
Solution -
B is correct.
Because the client is the trust/trustees, not the beneficiary. Mawar followed Standard
III(C) –Suitability by managing the trust assets in a way that would likely result in a
stable source of income while keeping the risk profile low, thereby complying with
the investment objectives of the trust.
178

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Cfa Level I Ethics Review Class

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cfa level I

ETHICAL AND PROFESSIONAL

Ethical conduct is most likely behavior that:

A. is perceived to be beneficial as per society’s ethical

Ethical conduct includes those actions that are perceived as beneficial

An investment fund manager has a finance degree and over 20

A. Yes, as part of the industry, he is providing a service to others.

For the investment fund manager to claim he is part of a

When an otherwise honest person allows the promise of a bonus

Discussions of receiving a bonus can have a disproportionate

Which of the following is most likely an example of an

A. “I’m aware of my ethical obligations.”

An overconfidence bias is shown by thinking that your intelligence

The relationship between an investment professional and her

A. has specialized knowledge, leading her to have more power.

Investment professionals have access to specialized knowledge and

What is most likely a critical aspect of the Consider phase of an

A. Seeking additional guidance

Seeking additional guidance in the Consider phase of the ethical

If you are seeking guidance from the firm’s code of ethics or

If you are seeking guidance from the firm’s code of ethics or

If you are characterizing clients, family, colleagues, and market

The Identify phase is typically the initial phase of the ethical

Which of the following is least likely a phase in an ethical

A. Consideration of situational influences, additional guidance, and

Multiple iterations of analysis is not a phase in the ethical decision-

The benefits of an ethical decision-making framework would least

A. limiting unintended consequences.

The benefits of an ethical decision-making framework are least

Guidance for Standards I–VII

A. Public disclosure of disciplinary sanctions

Because the two principles of the Rules of Procedure for Proceedings

Which of the following groups is most likely responsible for

A. Disciplinary Review Committee

Disclosure of confidential CFA exam information will most likely be

A. analysis of Proctor Reports.

Professional Conduct inquiries come from a number of sources including

Sanctions imposed by CFA Institute for violations of the CFA Institute

A. revocation of a CFA Charter.

Sanctions available to CFA Institute do not include monetary fines.

Which of the following is not a component of the CFA Institute Code of

A. Practice and encourage others to practice in a professional and

Which of the following statements related to requirements for the CFA

The CFA Institute Standards of Professional Conduct Standard V(B)–

A. disclose to clients and prospective clients significant limitations and

The statement, “When communicating investment performance

A. Knowledge of the Law

Performance Presentation is a sub-section of Standard III– Duties to

Which CFA Institute Standard of Professional Conduct most likely

Standard V–Investment Analysis, Recommendations, and Actions

Standard IV–Duties to Employers includes a sub-section entitled

When can a party, nonmember or firm, most likely claim compliance

A. notified the CFA Institute of their claim.

The Code and Standards apply to individual members of CFA Institute

Because by failing to adhere to the non-compete clause he agreed to abide by when

Because members and candidates must self-disclose on the annual Professional

Because Standard IV(C)–Responsibilities of Supervisors states that members

Standard III(E)–Preservation of Confidentiality requires members and

Standard III(C)–Suitability of the CFA Institute Standards of Professional

Standard III(C)–Suitability of the CFA Institute Standards of Professional

Because Grey’s actions do not violate Standard IV(A)– Duties to

Because Gravel violated the Integrity of Capital Markets by engaging in a

Because under Standard I(B) members and candidates must protect