Overview and Key Themes5 min
This chapter presents scenario-based applications of the CFA Institute Code of Ethics and Standards of Professional Conduct organized into thematic areas. Knowledge of the Law: members and candidates must understand and comply with applicable laws and must not assist or participate in violations; when encountering apparent noncompliance, they must escalate, dissociate, or refuse to participate in actions that violate law or ethical rules. Independence and Objectivity: professionals must avoid gifts, benefits, or arrangements that could reasonably be expected to compromise independence or objectivity; when personal political contributions or other benefits create a perceived linkage to future business, avoidance or disclosure is required. Misrepresentation and Communication: members must not make false or misleading statements about services, results, or facts; they must distinguish fact from opinion, avoid promises of guaranteed returns, and promptly disclose material changes in methodology or facts that affect investors. Misconduct: Standard I(D) prohibits professional conduct involving dishonesty, fraud, or deceit; personal actions outside work are not automatically violations unless they reflect adversely on professional integrity or competence. Competence: members must act with and maintain competence necessary for responsibilities, including taking steps before assuming supervisory roles. Material Nonpublic Information and Market Manipulation: members must not act or cause others to act on material nonpublic information and must not manipulate markets or misrepresent liquidity or shareholder counts to gain listing or investor interest. Duties to Clients: includes Loyalty, Prudence, and Care (act for client benefit), Fair Dealing (distribute material info so clients have fair opportunity), Suitability (reasonably inquire into client objectives/constraints and ensure recommendations consistent with total portfolio), Performance Presentation (be fair, accurate, complete; disclose relevant context), Preservation of Confidentiality (keep client information confidential unless exceptions apply). Duties to Employers: members must act for benefit of employer while balancing client interests; they must not misuse employer property or confidential client lists, must manage transitions ethically, and should use proper channels to report employer misconduct. Conflicts of Interest: avoid or disclose conflicts that could impair independence and objectivity, obtain written employer consent before accepting additional compensation arrangements, and disclose referral fees. Priority of Transactions: client and employer transactions must have priority over personal transactions; front-running and manipulating allocation after observing outcomes are prohibited. Responsibilities of Supervisors: supervisors must make reasonable efforts to ensure supervised persons comply with laws, rules, and the Code and Standards; if unable to exercise supervisory responsibility, they should not accept the role or must escalate and seek change. Investment Analysis and Diligence: analysts must exercise diligence, independence, and have reasonable basis supported by research; reliance on third-party research requires verification. Record Retention: maintain records supporting analyses, recommendations, and client communications. Conduct as CFA Program participants and reference to the CFA designation: candidates and members must not compromise program integrity, must not disclose exam content, and must correctly represent the right to use the CFA designation (maintain membership requirements such as dues and professional conduct statements). Across all scenarios, the appropriate response often involves disclosure, escalation to compliance or regulators where required, refusal to participate in unethical conduct, remediation, and careful documentation to protect clients and markets.

Key Points

  • Members must comply with applicable law and dissociate from violations (Standard I(A)).
  • Avoid gifts or actions that could impair independence and objectivity (Standard I(B)).
  • Do not misrepresent facts or guarantee returns; distinguish fact from opinion (Standard I(C)).
  • Supervisors must make reasonable efforts to ensure compliance by subordinates (Standard IV(C)).
  • Client interests and priority of client transactions must be maintained (Standards III and VI).
Client Duties and Conflicts5 min
This chapter presents scenario-based applications of the CFA Institute Code of Ethics and Standards of Professional Conduct organized into thematic areas. Knowledge of the Law: members and candidates must understand and comply with applicable laws and must not assist or participate in violations; when encountering apparent noncompliance, they must escalate, dissociate, or refuse to participate in actions that violate law or ethical rules. Independence and Objectivity: professionals must avoid gifts, benefits, or arrangements that could reasonably be expected to compromise independence or objectivity; when personal political contributions or other benefits create a perceived linkage to future business, avoidance or disclosure is required. Misrepresentation and Communication: members must not make false or misleading statements about services, results, or facts; they must distinguish fact from opinion, avoid promises of guaranteed returns, and promptly disclose material changes in methodology or facts that affect investors. Misconduct: Standard I(D) prohibits professional conduct involving dishonesty, fraud, or deceit; personal actions outside work are not automatically violations unless they reflect adversely on professional integrity or competence. Competence: members must act with and maintain competence necessary for responsibilities, including taking steps before assuming supervisory roles. Material Nonpublic Information and Market Manipulation: members must not act or cause others to act on material nonpublic information and must not manipulate markets or misrepresent liquidity or shareholder counts to gain listing or investor interest. Duties to Clients: includes Loyalty, Prudence, and Care (act for client benefit), Fair Dealing (distribute material info so clients have fair opportunity), Suitability (reasonably inquire into client objectives/constraints and ensure recommendations consistent with total portfolio), Performance Presentation (be fair, accurate, complete; disclose relevant context), Preservation of Confidentiality (keep client information confidential unless exceptions apply). Duties to Employers: members must act for benefit of employer while balancing client interests; they must not misuse employer property or confidential client lists, must manage transitions ethically, and should use proper channels to report employer misconduct. Conflicts of Interest: avoid or disclose conflicts that could impair independence and objectivity, obtain written employer consent before accepting additional compensation arrangements, and disclose referral fees. Priority of Transactions: client and employer transactions must have priority over personal transactions; front-running and manipulating allocation after observing outcomes are prohibited. Responsibilities of Supervisors: supervisors must make reasonable efforts to ensure supervised persons comply with laws, rules, and the Code and Standards; if unable to exercise supervisory responsibility, they should not accept the role or must escalate and seek change. Investment Analysis and Diligence: analysts must exercise diligence, independence, and have reasonable basis supported by research; reliance on third-party research requires verification. Record Retention: maintain records supporting analyses, recommendations, and client communications. Conduct as CFA Program participants and reference to the CFA designation: candidates and members must not compromise program integrity, must not disclose exam content, and must correctly represent the right to use the CFA designation (maintain membership requirements such as dues and professional conduct statements). Across all scenarios, the appropriate response often involves disclosure, escalation to compliance or regulators where required, refusal to participate in unethical conduct, remediation, and careful documentation to protect clients and markets.

Key Points

  • Suitability requires reasonable inquiry into client objectives and constraints before recommending investments.
  • Fair dealing requires providing equal opportunity to act on recommendations; differential paid services are allowed if disclosed and non-prejudicial.
  • Confidential client information must be protected; unauthorized copying or downloading is a violation.
  • Referral fees and bonuses must be disclosed to clients and employers (Standard VI(C)).
Supervision, Employers, and Records5 min
This chapter presents scenario-based applications of the CFA Institute Code of Ethics and Standards of Professional Conduct organized into thematic areas. Knowledge of the Law: members and candidates must understand and comply with applicable laws and must not assist or participate in violations; when encountering apparent noncompliance, they must escalate, dissociate, or refuse to participate in actions that violate law or ethical rules. Independence and Objectivity: professionals must avoid gifts, benefits, or arrangements that could reasonably be expected to compromise independence or objectivity; when personal political contributions or other benefits create a perceived linkage to future business, avoidance or disclosure is required. Misrepresentation and Communication: members must not make false or misleading statements about services, results, or facts; they must distinguish fact from opinion, avoid promises of guaranteed returns, and promptly disclose material changes in methodology or facts that affect investors. Misconduct: Standard I(D) prohibits professional conduct involving dishonesty, fraud, or deceit; personal actions outside work are not automatically violations unless they reflect adversely on professional integrity or competence. Competence: members must act with and maintain the competence necessary for responsibilities, including taking steps before assuming supervisory roles. Material Nonpublic Information and Market Manipulation: members must not act or cause others to act on material nonpublic information and must not manipulate markets or misrepresent liquidity or shareholder counts to gain listing or investor interest. Duties to Clients: includes Loyalty, Prudence, and Care (act for client benefit), Fair Dealing (distribute material info so clients have fair opportunity), Suitability (reasonably inquire into client objectives/constraints and ensure recommendations consistent with total portfolio), Performance Presentation (be fair, accurate, complete; disclose relevant context), Preservation of Confidentiality (keep client information confidential unless exceptions apply). Duties to Employers: members must act for benefit of employer while balancing client interests; they must not misuse employer property or confidential client lists, must manage transitions ethically, and should use proper channels to report employer misconduct. Conflicts of Interest: avoid or disclose conflicts that could impair independence and objectivity, obtain written employer consent before accepting additional compensation arrangements, and disclose referral fees. Priority of Transactions: client and employer transactions must have priority over personal transactions; front-running and manipulating allocation after observing outcomes are prohibited. Responsibilities of Supervisors: supervisors must make reasonable efforts to ensure supervised persons comply with laws, rules, and the Code and Standards; if unable to exercise supervisory responsibility, they should not accept the role or must escalate and seek change. Investment Analysis and Diligence: analysts must exercise diligence, independence, and have reasonable basis supported by research; reliance on third-party research requires verification. Record Retention: maintain records supporting analyses, recommendations, and client communications. Conduct as CFA Program participants and reference to the CFA designation: candidates and members must not compromise program integrity, must not disclose exam content, and must correctly represent the right to use the CFA designation (maintain membership requirements such as dues and professional conduct statements). Across all scenarios, the appropriate response often involves disclosure, escalation to compliance or regulators where required, refusal to participate in unethical conduct, remediation, and careful documentation to protect clients and markets.

Key Points

  • Supervisors must ensure effective compliance systems and reasonable oversight.
  • Taking proprietary client lists or records when departing is a breach of employer loyalty.
  • Record retention policies must support and document investment recommendations and suitability analyses.
  • When supervisors cannot perform duties because of firm structure or lack of authority, they should decline the role or escalate.

Questions

Question 1

According to Standard I(A) Knowledge of the Law, if you discover your firm is systematically overcharging clients for a pass-through expense, your best immediate action is to:

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Question 2

A CEO learns a long-time client account shows patterns consistent with money laundering. The CEO considers the client's status and vague descriptions of transfers credible and approves alerts without further inquiry. Under Standard I(A), this conduct is:

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Question 3

An adviser signs documents on behalf of clients without their signatures to avoid account overdrafts because the clients previously agreed verbally. This action most likely constitutes:

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Question 4

A CFA charterholder plans to give a political donation to a candidate who may influence state pension allocations and expects this to benefit her firm. The safest course under Standard I(B) Independence and Objectivity is to:

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Question 5

If an adviser promises clients they will 'make up' an immediate account penalty through superior investment returns from a volatile equity product, this claim is:

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Question 6

A firm includes a key team member in a proposal. Before contract award that person leaves the firm. Under Standard I(C) Misrepresentation, the firm should:

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Question 7

A CEO publicly posts on social media a specific purchase price for taking the company private before any agreement or funding exists. The CEO later admits it was a joke. This action is:

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Question 8

An employee participates in peaceful civil disobedience and is arrested and convicted of minor offenses unrelated to work. Under Standard I(D) Misconduct, is this conduct automatically a violation?

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Question 9

A newly promoted compliance officer with little experience accepts the role despite lacking authority to supervise senior family members who control the firm. Under Standard IV(C), the compliance officer should have:

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Question 10

An employee downloads confidential client lists from the employer before leaving and intends to notify former clients of their new role. Under Standard IV(A) Loyalty, this action is:

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Question 11

A portfolio manager allocates most profitable block trade allocations to accounts he and his spouse control and allocates losers to large client accounts. This practice violates:

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Question 12

An analyst is offered a bonus by issuers to include them in the firm's research universe and participates in selection decisions. Under Standard IV(B) Additional Compensation Arrangements, the analyst should:

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Question 13

A manager uses the firm's soft dollar account to pay exam fees for professional education that benefits the manager personally. Under Standard III(A), this use of client commissions is:

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Question 14

An analyst overhears lawyers discussing a pending acquisition in a public setting and subsequently trades the target company shares before public announcement. Under Standard II(A), the analyst's trade is:

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Question 15

A ratings agency changes its DSCR calculation method which materially increases ratings but does not disclose the change. Under Standard V(B), this omission is:

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Question 16

A manager regularly uses an error-correction policy to fabricate 'forgotten' prior orders, charging the price difference to an internal error account and then selling for a client profit. This behavior is:

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Question 17

An analyst joins a new firm as a supervisor but has not trained in supervisory duties. Under Standard I(E) Competence, the analyst should:

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Question 18

A firm claims compliance with the GIPS standards for performance presentation using preexisting composite returns, but fails to disclose that the results are from pre-registration separate accounts later folded into a registered fund. Under Standard III(D) Performance Presentation this omission is:

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Question 19

An adviser encourages clients to move retirement assets into an illiquid, highly concentrated leveraged local fund to capture tax benefits, without fully assessing clients' objectives or diversification needs. This likely violates:

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Question 20

If a firm provides a regular monthly recommendation update to all clients but offers a weekly premium report for an annual fee available to any client, this practice is:

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Question 21

A broker arranged false shareholders to meet a listing spread requirement and provided fake names and addresses. The broker later profited as the stock appreciated. This conduct is best described as:

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Question 22

A portfolio manager is offered soft-dollar research in exchange for client commissions and also a low-fee execution service where commissions count toward previous soft-dollar commitments. For accounts that prohibit soft dollars, the manager should:

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Question 23

An adviser receives a significant incentive for joining a startup by bringing clients with minimum commitments. Under Standard IV(A), a member considering joining should:

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Question 24

A manager obtains written permission from the employer to accept outside compensation from an issuer for research selection. What additional step is required under the Standards?

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Question 25

A manager discovers an analyst's research relied on forged documents from the issuer. The manager subsequently uses that research in portfolio decisions. Which parties likely violated Standard V(A) Diligence and Reasonable Basis?

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Question 26

Under Standard III(E) Preservation of Confidentiality, an employee who downloads firm client data to a personal server for telework and later has it hacked has:

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Question 27

A student in a CFA prep course hears classmates describe the exam difficulty and topics in general terms. Their instructor later uses these general impressions to advise future students to study broadly. Under Standard VII(A), this conduct is:

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Question 28

A manager desires to accept third-party-paid travel to a conference hosted by a current investment manager used by the manager's pension fund. Which acceptance is least likely to violate independence and objectivity under Standard I(B)?

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Question 29

An adviser recommends clients convert pension assets into self-managed funds invested in direct property without assessing clients' time, expertise, liquidity needs, or diversification. This violates which obligation most directly?

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Question 30

A manager books weekend travel because rates are cheaper and claims the client is billed for weekend accommodation and meals. Under Standard III(A) Loyalty, Prudence, and Care, which expenses are most likely chargeable to the municipal client?

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Question 31

A research analyst overhears administrators mention a possible merger in confidence. He adds the stock to his firm's restricted list and does not trade. His employer told no one else. Is his action compatible with Standard II(A) Material Nonpublic Information?

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Question 32

A portfolio manager records conversations with a supervisor alleging pressure to sell proprietary products and later provides those recordings to the regulator when internal complaints fail. Under Standard IV(A) Loyalty and supervisory duties, this whistleblowing is:

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Question 33

A firm claims GIPS compliance. Which of the following statements is true about who may claim compliance with GIPS?

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Question 34

A firm creates composites to present strategy returns. Which practice would violate the GIPS intent?

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Question 35

A trader shares imminent block trade details with friends who then buy the same securities before the fund executes its block. This behavior is:

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Question 36

A manager uses client commissions to pay for the firm's operating expenses. Which Standard is most directly violated?

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Question 37

An adviser regularly fails to update client records and only updates profiles 'when time permits.' Under Standard V(C) Record Retention, this practice is:

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Question 38

An adviser sells a security recommendation to a client before determining the client's risk tolerance and investment constraints. Which Standard is most directly implicated?

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Question 39

A manager places an account on the restricted list after learning of confidential merger talks and then trades for other firm accounts. Which action would be most consistent with Standard II(A)?

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Question 40

A supervisor allows a remote employee to operate with minimal oversight; the remote employee later engages in undisclosed commission-splitting with another firm. Under Standard IV(C), the supervisor is:

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Question 41

A manager sells a client's most liquid holdings to cover a margin shortfall after unilateral cancellation of a planned exchange because the manager forged client signatures earlier. Which Standards are implicated?

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Question 42

An analyst publicly states that a mutual fund 'will earn 10 percent each year' based on historical performance. This statement is:

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Question 43

A firm claims to fully comply with GIPS but excludes terminated accounts from composites to avoid poor returns. This practice:

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Question 44

A research head promotes a junior analyst who had no role in covering a client and then asks the junior to write a report on a firm the employer banks for. The junior discloses the banking relationship in the report and issues a nuanced buy. Under Standards relating to conflicts and independence, the junior should:

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Question 45

An employee secretly takes client funds while employed and later is prosecuted. The compliance officer ignored repeated warnings of the employee's behavior. Under the Code and Standards, who faces potential violation for failing to act?

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Question 46

A manager allocates trades from an omnibus block after market close, choosing allocations that favor accounts with better performance history. This selective allocation practice is:

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Question 47

A firm representative advertises 'completion of CFA Program' as enhancing skills and career prospects. Is this claim consistent with Standard VII(B)?

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Question 48

A member's CFA Institute membership lapsed for nonpayment of dues. He continues to use 'CFA' after his name on business cards. This behavior is:

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Question 49

A manager uses client brokerage commissions to purchase research that helps the firm but not directly the client accounts that paid commissions. Under Standard III(A) this action is:

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Question 50

A member refuses an employer's order to change a sell recommendation to a buy to win investment banking business. Under Standard I(B) Independence and Objectivity, the analyst should:

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