Learning Module 3 Guidance for Standards I–VII

50 questions available

Overview and Purpose5 min
This chapter provides interpretive guidance, recommended procedures, and examples for applying Standards I through VII of the CFA Institute Code of Ethics and Standards of Professional Conduct. It stresses that members and candidates must: (1) comply with applicable laws and choose the stricter rule when the Code and local law conflict (Standard I(A)); (2) preserve independence and objectivity by limiting or disclosing gifts/benefits and protecting research integrity and firewalls between business units (Standard I(B)); (3) avoid misrepresentation and plagiarism, ensure marketing and performance communications are accurate and not misleading, and maintain control over proprietary and third-party content (Standard I(C)); (4) not engage in dishonest, fraudulent, or deceitful conduct and avoid behavior that reflects adversely on professional reputation (Standard I(D)); (5) act with and maintain competence appropriate to one’s role and update knowledge and skills as responsibilities change (Standard I(E)).

Key Points

  • Chapter explains Standards I–VII application and firm procedures.
  • Follow stricter applicable law when conflicts arise with the Code and Standards.
  • Independence and objectivity must be protected via limits on gifts and robust firewalls.
  • Misrepresentation, plagiarism, and misleading marketing/performance materials are prohibited.
  • Maintain and develop professional competence proportionate to duties.
Integrity of Capital Markets (Standard II)5 min
Standard II addresses integrity of capital markets: do not trade or cause others to trade on material nonpublic information; understand materiality and whether information is public; adopt compliance, disclosure, firewall, and pre-clearance procedures; and avoid information- or transaction-based market manipulation. Guidance defines materiality (information likely to affect price) and nonpublic status (not broadly disseminated). Mosaic theory permits acting on a mix of public and nonmaterial nonpublic information, but selective disclosure and tipping are prohibited. Recommended procedures include watch/restricted lists, physical and informational barriers, documentation of procedures, and monitoring of proprietary and personal trading.

Key Points

  • Material nonpublic information cannot be used for trading or tipping.
  • Mosaic theory allows analysis of public and nonmaterial nonpublic pieces, but not trading on tips.
  • Firewalls, watch/restricted lists, and preclearance help prevent insider information misuse.
  • Information-based and transaction-based market manipulation are prohibited.
  • Firms should have documented disclosure and escalation procedures.
Duties to Clients (Standard III)6 min
Standard III (Duties to Clients) requires loyalty, prudence, and care: know the client, document an investment policy statement, assess suitability and total-portfolio effects, pursue best execution, disclose conflicts and fees, vote proxies prudently, and present performance fairly, accurately, and with appropriate benchmarks and disclosures (including compliance with GIPS where applicable). Fair dealing obliges firms and advisers to give all clients a fair opportunity to act on recommendation changes; suitability requires reasonable inquiry into client objectives, constraints, and risk tolerance; performance presentation must be fair, accurate, and complete; and confidentiality rules protect client information unless illegal activity, legal compulsion, or client consent allows disclosure. Firms should create written IPSs, disclosure policies, and regular review schedules.

Key Points

  • Clients’ interests take priority: documents and update investment policy statements.
  • Suitability analysis must precede recommendations and consider the total portfolio.
  • Fair dealing requires equitable dissemination and trade allocation procedures.
  • Performance presentations must be accurate, with meaningful benchmarks and disclosures.
  • Maintain client confidentiality; follow legal exceptions and firm policies.
Duties to Employers and Supervisory Responsibilities (Standard IV)5 min
Standard IV covers duties to employers and supervisory responsibilities: act for the benefit of the employer in employment matters; avoid outside compensation or activities that conflict with employer interests unless disclosed and approved; do not misuse employer property or confidential records upon departure; and, if a supervisor, make reasonable efforts to ensure staff compliance with laws, rules, the Code and Standards, and firm policies. Supervisors should implement compliance procedures, codes of ethics, training, monitoring, audits, and appropriate incentive structures. If supervisory duties cannot reasonably be performed, the supervisor should decline or escalate the responsibility.

Key Points

  • Employees must act for their employer’s benefit and not cause harm or misuse confidential property.
  • Obtain written consent for outside compensation or activities that could conflict with employer interests.
  • Supervisors must establish, communicate, and enforce compliance systems, training, and audits.
  • When leaving an employer, avoid soliciting clients or taking employer records without permission.
  • Whistleblowing may be appropriate when internal remediation fails and client/market harm is present.
Investment Analysis, Recommendations, and Records (Standard V)6 min
Standard V requires diligence and reasonable basis for analysis, validation and scenario testing for quantitative models, careful use/verification of third-party or issuer-paid research, documentation/record retention supporting analyses and recommendations, and clear communications with clients regarding investment processes, fees, risks, limitations, and distinguishing fact from opinion. Firms should maintain records (recommended minimum seven years), disclose methodologies and model limitations, conduct due diligence on subadvisers, and adopt review and approval processes for research and model-based advice.

Key Points

  • Exercise thorough, independent research; validate quantitative models and stress-test assumptions.
  • Verify third-party research before relying on it and document sources and assumptions.
  • Retain supporting records to substantiate analyses, recommendations, and communications.
  • Disclose investment process, costs, material changes, limitations, and risks to clients.
  • Distinguish clearly between fact and opinion in all client communications.
Conflicts of Interest (Standard VI) and CFA Responsibilities (Standard VII)5 min
Standard VI requires avoiding or disclosing conflicts of interest that could impair independence and objectivity; disclosures must be prominent, clear, and effective. Members must prioritize client and employer transactions over personal trades (priority of transactions), disclose referral fees, and appropriately manage gifts, travel funding, and issuer-paid research. Standard VII prohibits conduct that undermines CFA Institute programs or misuses the CFA designation; candidates and members must not disclose confidential exam content, must represent CFA status accurately, and must cooperate with professional conduct investigations while protecting confidentiality. Firms should adopt disclosure templates, personal-trading policies, preclearance and reporting, conflict-management practices, and public statements on CFA usage.

Key Points

  • Avoid conflicts when possible; otherwise disclose fully and prominently to clients and employers.
  • Client and employer transactions must have priority over personal trading; implement preclearance and reporting.
  • Referral fees and payments from third parties must be disclosed to clients and employers.
  • Do not disclose confidential CFA Program exam content; use CFA designation accurately and honestly.
  • Firms should maintain written conflict policies, personal-trading rules, and firmwide disclosure templates.

Questions

Question 1

Under Standard I(A) Knowledge of the Law, if a firm policy is less strict than the CFA Code and Standards, what must a CFA Institute member do in that jurisdiction?

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Question 2

An analyst is offered payment by an issuer to produce a research report on that issuer. According to the guidance for Standard I(B) and Standard V(A), which practice best preserves research independence?

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Question 3

You overhear a senior manager at your firm mentioning confidential board discussions about a pending acquisition that would be material to the target's stock price. According to Standard II(A), your best immediate action is to:

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Question 4

A research analyst learns that a corporate client will miss its next-quarter earnings target, but this has not been publicly announced. Under Standard II(A), which of the following is correct?

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Question 5

Which action best demonstrates appropriate independence and objectivity under Standard I(B) when attending an issuer-hosted site visit paid by the issuer?

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Question 6

A portfolio manager receives information that an upcoming IPO will be heavily oversubscribed. As a best practice under Standard III(B) Fair Dealing and Standard I(B), how should IPO allocations be handled?

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Question 7

Which record-retention practice best aligns with Standard V(C) Record Retention for an investment analyst who relies on third-party research?

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Question 8

A firm changes its quantitative model inputs and this produces materially different portfolio attributions. Under Standard III(D) and V(B), how should the firm communicate this change to clients?

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Question 9

A junior analyst proposes to include a short promotional piece on the firm website claiming the firm’s team has unique proprietary analytics. Under Standard I(C) and V(A), what must the firm ensure before posting?

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Question 10

An adviser receives a call from a client requesting an investment that deviates materially fromthe client’s documented IPS. Under Standard III(C) Suitability, what is the adviser’s most appropriate immediate step?

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Question 11

You are evaluating whether to hire an external manager for a specific asset class. According to Standard V(A), which due diligence action is least acceptable?

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Question 12

A fund claims compliance with the GIPS standards. What additional step adds strongest independent credibility to the claim?

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Question 13

Under Standard IV(B) Additional Compensation Arrangements, which of the following must a member do before accepting outside payment for client referrals?

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Question 14

An analyst repackages third-party research to clients and claims it as the firm’s proprietary analysis. Under Standard I(C), what must the analyst do instead?

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Question 15

A junior advisor discovered an accounting error in a prior performance report distributed to clients. Under Standard III(D) Performance Presentation, the advisor should:

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Question 16

Which practice best meets the requirements of Standard I(E) Competence when an analyst’s role expands to cover new asset classes?

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Question 17

Under Standard VI(A) Avoid or Disclose Conflicts, which disclosure is required when a portfolio manager’s spouse receives special IPO allocations from an issuer that the manager follows?

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Question 18

Your firm considers buying an analyst’s proprietary quantitative screening tool from a vendor. Under Standard V(A) and I(C), what should the firm require before adoption?

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Question 19

An analyst publishes a report quoting an influential blogger as saying a drug trial’s early results were disappointing. Under Standard I(C) Misrepresentation and II(A), what is required?

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Question 20

Which is the strongest action a supervisor should take under Standard IV(C) when an analyst repeatedly fails to follow the firm’s research due-diligence checklist?

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Question 21

A portfolio manager places a large block order for a thinly traded stock on behalf of a client. Best execution and Standard III(A) require that the manager:

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Question 22

When a firm claims compliance with the GIPS standards, which of the following is required for the firm’s performance presentation under Standard III(D)?

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Question 23

If an employee uncovers apparent illegal conduct by supervisors and internal efforts to remedy it have failed, Standard I(A) suggests the employee should next:

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Question 24

A senior analyst receives an expensive gift from a broker after giving the broker significant execution volume. Under Standard I(B) and VI(A), what is the appropriate firm policy action?

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Question 25

When an adviser provides different service tiers (standard vs premium) at different price points, which of the following is required by Standard III(B) Fair Dealing?

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Question 26

A fund includes only top-performing client accounts in its marketing composite to highlight strong results. Under GIPS and Standard III(D), this practice is:

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Question 27

Under Standard VI(B) Priority of Transactions, when a manager has a personal beneficial interest in a security that the firm is about to purchase for multiple client portfolios, the manager should:

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Question 28

A candidate who just completed a CFA exam wants to post exam impressions online. Under Standard VII(A), which is acceptable?

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Question 29

A fund manager asks a junior analyst to incorporate ESG scores from an external vendor into the firm’s model. Under Standards V(A) and I(C), what steps should the analyst take before using the vendor’s scores in client-facing models?

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Question 30

Which approach best satisfies Standard III(E) Preservation of Confidentiality when a regulator requests client records during an investigation?

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Question 31

Which of the following allocation procedures best satisfies Standard III(B) Fair Dealing for partial fills of block trades across client accounts?

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Question 32

A manager discovers a modeling error that materially overstated portfolio performance used in marketing materials. Standard III(D) requires that the manager:

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Question 33

Under Standard I(C), when a compliance officer becomes aware that marketing materials omit discussion of significant fund leverage that increases risk, the officer should:

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Question 34

A portfolio manager’s compensation is tied to quarterly relative performance. Standard I(B) and III(A) raise concerns because such a structure most likely:

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Question 35

Which personal-trading policy best satisfies Standards I(B), VI(B), and IV(C) when investment professionals may trade securities also held by clients?

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Question 36

An adviser provides a brief performance snapshot to a prospect. Under Standard III(D), what disclosure should accompany a short-form yield claim?

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Question 37

When is it acceptable under Standard VI(C) to accept a referral fee paid by a product provider for client introductions?

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Question 38

An adviser is approached by a candidate in the CFA Program who wants to add "CFA Level II" to their business card after passing Level II. Under Standard VII(B), what should the adviser advise the candidate?

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Question 39

If an employee doubts the adequacy of their firm’s AML procedures while handling client accounts, Standard I(A) and IV(C) suggest the employee should first:

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Question 40

A manager has adopted an enhanced firewall between research and investment banking. Which of the following changes best demonstrates compliance with Standard I(B) Independence and Objectivity?

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Question 41

Which action would most likely violate Standard I(D) Misconduct if committed by an investment professional?

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Question 42

If a quantitative model used to price structured products was discovered to contain optimistic assumptions not disclosed to investors, which Standards are implicated and what is the appropriate remedial step?

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Question 43

A candidate is preparing social media content to promote their exam tutoring business. Under Standard VII(B), which statement is allowed?

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Question 44

Which behavior would violate Standard VI(A) Avoid or Disclose Conflicts when a portfolio manager’s firm underwrites an issuer and the manager’s team covers the issuer’s research?

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Question 45

During a market-moving webinar, an analyst mentions she is 'considering' raising price targets for a stock based on private conversations with management. Under Standard II(A) and V(B), the analyst should:

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Question 46

Which course of action fulfills Standard IV(B) when an adviser is offered a sales commission by a product provider for steering clients to its funds?

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Question 47

A manager claims in marketing materials: 'Our proprietary model guarantees 8% annual returns.' Under Standard I(C) and V(A), this claim is:

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Question 48

Which supervisory control best addresses concerns in Standards IV(C) and II(A) about insider information spreading within a multi-service firm?

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Question 49

An adviser alters an account’s benchmark after a period of poor performance so the returns look better. Under Standard III(D) and V(C), this conduct is:

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Question 50

A firm wants to claim it complies with the CFA Institute Code and Standards but only follows select provisions. Under the guidance, is the selective-claim approach allowed?

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