Complete Ethics practice
163 questions with answers and explanations.
Choose a module or work from start to finish. Each explanation identifies the governing concept and the decisive fact. Answers are collapsed by default.
The page contains only Ethics questions from the current canonical 2027 bank; no questions from other CFA topics are included.
Module 1
Ethics, Trust, the Code, and Enforcement
Questions 1-11 · 11 questions
Question 1 · Module 1
A country's advertising law allows advisers to omit transaction costs from a short online promotion. Elena includes expected returns but omits large recurring costs, even though the omission is likely to mislead ordinary clients. What is Elena's most appropriate course of action?
- AFollow the law because legal permission ends the ethical analysis.
- BOmit both returns and costs because ethics prohibits all short promotions.
- CConsider the effect on clients and communicate the costs fairly despite the legal permission.
Check answer and explanation
Correct answer: C
Primary concept: Law establishes a minimum; ethical duties may demand more.
Decisive fact: The permitted omission is likely to mislead clients about the economic result.
Explanation: C is best because professional judgment must consider fairness, client understanding, and indirect consequences, not only whether conduct is legal. A is wrong because legality does not automatically make communication ethical. B is wrong because a concise promotion is not prohibited; it must simply avoid misleading omissions.
Question 2 · Module 1
Which statement best explains why trust has economic value in investment markets?
- ATrust reduces verification and monitoring costs and supports participation.
- BTrust guarantees that every investment recommendation will be profitable.
- CTrust eliminates the need for regulation and professional competence.
Check answer and explanation
Correct answer: A
Primary concept: Trust is market infrastructure.
Decisive fact: Reliable information and behavior reduce the friction of delegation.
Explanation: A is correct because clients are more willing to delegate capital when they can rely on the profession's information, competence, and conduct. B is wrong because trust does not remove investment risk. C is wrong because trust is reinforced by competence, rules, oversight, and accountability rather than replacing them.
Question 3 · Module 1
When facing an unfamiliar ethical problem, a portfolio manager should most appropriately begin by:
- Aidentifying the relevant facts, stakeholders, duties, and missing information.
- Bselecting the action that protects the manager's reputation.
- Casking whether the proposed action produced a good result in a similar case.
Check answer and explanation
Correct answer: A
Primary concept: A defensible decision begins with disciplined fact identification.
Decisive fact: The problem is unfamiliar, so intuition alone is unreliable.
Explanation: A is correct because the manager must understand who may be affected and which duties govern before comparing alternatives. B is wrong because self-protection is not the controlling objective. C is wrong because a favorable outcome does not prove that the process or conduct was ethical.
Question 4 · Module 1
A normally careful analyst approves a weak report minutes before a deadline because everyone on the team says, "Just send it." Which situational influence most directly increases the ethical risk?
- ALong-term orientation.
- BTime pressure combined with group conformity.
- CIndependent escalation.
Check answer and explanation
Correct answer: B
Primary concept: Situational pressure can bend otherwise sound judgment.
Decisive fact: Urgency and team consensus discourage independent review.
Explanation: B is correct because time scarcity and conformity are predictable sources of poor ethical decisions. A is wrong because short-term, not long-term, focus is the concern. C is wrong because independent escalation is a control that may reduce the risk.
Question 5 · Module 1
Which combination most strongly supports classifying investment management as a profession?
- ASpecialized knowledge, service orientation, common standards, continuing competence, and oversight.
- BHigh compensation, private information, and freedom from external review.
- CCommercial success, guaranteed entry, and loyalty only to the employer.
Check answer and explanation
Correct answer: A
Primary concept: A profession earns trust through expertise and accountable service.
Decisive fact: Professional status depends on standards and obligations, not merely specialized work.
Explanation: A is correct because enforceable standards, specialized competence, service to others, and accountability distinguish a profession from ordinary employment. B is wrong because private information and lack of oversight undermine trust. C is wrong because professional status neither guarantees entry nor places employer interests above client and market duties.
Question 6 · Module 1
A candidate's employer has no policy on discussing exam content. After an exam, the candidate shares a confidential tested topic in a staff chat. Who bears responsibility under the Code and Standards?
- AOnly the employer, because it failed to adopt a policy.
- BThe candidate personally, because the Code and Standards bind covered individuals.
- CNo one, because workplace messages are private.
Check answer and explanation
Correct answer: B
Primary concept: Members and candidates carry personal responsibility for compliance.
Decisive fact: The candidate personally disclosed confidential exam content.
Explanation: B is correct because the candidate personally disclosed protected tested content, and members and candidates remain individually bound by the Standards even when an employer has no matching policy. A is wrong because firm controls support but do not replace the candidate's own duty. C is wrong because a private workplace chat is still an unauthorized audience; the confidentiality obligation does not depend on whether the message is public.
Question 7 · Module 1
Following a professional conduct investigation, which sanction is within CFA Institute's authority?
- AImprisoning the candidate.
- BRevoking the candidate's securities licence.
- CSuspending or terminating the candidate's participation in the CFA Program.
Check answer and explanation
Correct answer: C
Primary concept: CFA Institute may impose program- and membership-related sanctions.
Decisive fact: Program participation lies within CFA Institute's institutional authority.
Explanation: C is correct because CFA Institute may impose professional and program sanctions, including public censure and suspension or termination of candidacy or membership. A is wrong because imprisonment is a criminal penalty that only a competent court or state authority may impose. B is wrong because a securities licence is issued and revoked by a government regulator, whereas CFA Institute's authority concerns its own programs, membership, and professional designations.
Question 8 · Module 1
Professional Conduct receives a credible anonymous public post alleging that a member fabricated credentials. Which statement is most accurate?
- AThe information may support opening a case and requesting a response.
- BA case can begin only from the member's annual disclosure.
- CAnonymous information must be ignored even if corroborated.
Check answer and explanation
Correct answer: A
Primary concept: A conduct review can arise from several credible information sources.
Decisive fact: The allegation is credible and can be investigated.
Explanation: A is correct because public information, regulatory action, written complaints, self-disclosures, and other credible evidence may trigger inquiry. B is wrong because it incorrectly limits inquiries to annual self-disclosures, excluding complaints, public information and other credible triggers. C is wrong because anonymity does not make verifiable information unusable.
Question 9 · Module 1
Which statement most accurately distinguishes the Code of Ethics from the Standards of Professional Conduct?
- AThe Code applies only to charterholders, while the Standards apply only to candidates.
- BThe Code contains criminal law, while the Standards contain voluntary suggestions.
- CThe Code states high-level professional ideals, while the Standards translate them into enforceable conduct requirements.
Check answer and explanation
Correct answer: C
Primary concept: The Code supplies direction; the Standards govern conduct.
Decisive fact: One is aspirational in form and the other specifies practical duties.
Explanation: C is correct because the Code articulates broad professional commitments and ideals, while the Standards turn those commitments into specific conduct duties used in professional enforcement. A is wrong because both the Code and Standards apply to covered members and candidates rather than being split between them. B is wrong because neither document is criminal law, and the Standards are enforceable professional requirements rather than voluntary suggestions.
Question 10 · Module 1
Which action is most directly part of a member's continuing professional conduct obligations?
- ACompleting the required annual professional conduct self-disclosure truthfully.
- BDelegating all reporting obligations to the employer.
- CReporting every suspected violation publicly before investigation.
Check answer and explanation
Correct answer: A
Primary concept: Covered persons must cooperate with professional conduct processes and make required disclosures accurately.
Decisive fact: Annual self-disclosure is an individual obligation.
Explanation: A is correct because the required annual professional conduct statement is a personal representation, so the member must complete it truthfully and cannot outsource its accuracy. B is wrong because an employer cannot assume or discharge an individual's disclosure and cooperation duties. C is wrong because the Standards do not require every unverified suspicion to be announced publicly; evidence, confidentiality, applicable law, and authorized reporting processes govern the response.
Question 11 · Module 1
A firm's compliance manual permits an analyst to publish a recommendation on a company whose shares she owns, provided the holding is listed in the report's appendix. The analyst follows the manual exactly. Her colleague argues that the analysis is nonetheless incomplete. The colleague's argument is best described as:
- Aincorrect, because conduct that complies with the firm's written policy cannot be unethical
- Bcorrect, because any personal holding must be sold before research on that company may be published
- Ccorrect, because an ethical analysis also asks what the disclosure does for the reader, not only whether a rule was followed
Check answer and explanation
Correct answer: C
Primary concept: Ethics can require more than legal compliance
Decisive fact: Permission in a compliance manual does not remove the need to identify and disclose a material conflict of interest.
Explanation: Option C is correct. An ethical analysis asks what a person should do, not only what a rule allows, and it weighs the foreseeable effects on the people affected. A holding buried in an appendix may satisfy the manual while leaving an ordinary reader unaware of the conflict when they read the recommendation, so the question the colleague is raising is a real one. Option A treats compliance as the end of the analysis; a policy sets a floor, and following it does not answer whether the disclosure is effective. Option B overstates the requirement: the Standards do not require disposal of a holding, they require the conflict to be avoided where reasonably possible or disclosed prominently and effectively.
Option A is incorrect: treats a written policy as the whole of the ethical question
Option B is incorrect: invents a disposal requirement in place of avoidance or effective disclosure
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Module 2
Standard I: Professionalism
Questions 12-31 · 20 questions
Question 12 · Module 2
Mika works in Country A, where local law requires research records to be retained for ten years. Her global employer's policy requires seven years, and the Code and Standards impose no longer applicable period. What should Mika do?
- AFollow the seven-year employer policy because it is global.
- BRetain the records for ten years.
- CAverage the two periods and retain the records for eight and a half years.
Check answer and explanation
Correct answer: B
Primary concept: Follow the stricter applicable requirement when requirements conflict.
Decisive fact: A binding local law requires the longer period.
Explanation: B is correct because the applicable legal requirement is stricter. A is wrong because the shorter employer retention policy cannot displace the stricter applicable law. C is wrong because conflicting requirements are not averaged; the professional must identify and follow the stricter duty.
Question 13 · Module 2
No law or regulation addresses a particular advisory activity in Nari's country. Which requirement should Nari follow?
- ANo requirement, because silence in local law creates a safe harbor.
- BThe Code and Standards.
- COnly informal industry custom, even if it is less strict.
Check answer and explanation
Correct answer: B
Primary concept: When no applicable law governs, follow the Code and Standards.
Decisive fact: The jurisdiction has not displaced the professional requirements.
Explanation: B is correct because when no applicable law or regulation governs the activity, the member or candidate must still comply with the Code and Standards as the controlling professional requirement. A is wrong because legal silence creates no ethical safe harbor. C is wrong because an informal industry custom, particularly one that is less strict, cannot replace the express duties imposed by the Code and Standards.
Question 14 · Module 2
An analyst discovers that her team is knowingly distributing an unlawful product. She objects, but the team continues. What should she most appropriately do next under Standard I(A)?
- AStay silent because she did not design the product.
- BContinue participating but keep a private note of her objection.
- CAttempt to stop the conduct, dissociate from it, and document and escalate as appropriate.
Check answer and explanation
Correct answer: C
Primary concept: Do not knowingly participate in or assist a violation; dissociate when necessary.
Decisive fact: The violation continues after the analyst raises the concern.
Explanation: C is correct because a private disagreement is insufficient if the analyst remains involved. A is wrong because participation can create responsibility even without product authorship. B is incorrect because documenting the concern does not end the analyst's continuing involvement.
Question 15 · Module 2
An issuer tells an analyst that future access to management depends on a favorable recommendation. Which Standard is most directly threatened?
- AStandard I(C), Misrepresentation.
- BStandard I(B), Independence and Objectivity.
- CStandard I(D), Misconduct.
Check answer and explanation
Correct answer: B
Primary concept: Protect professional judgment from pressure or benefits that could reasonably compromise it.
Decisive fact: The issuer conditions valuable access on the desired research outcome.
Explanation: B is correct because the threat targets the analyst's independent judgment. A is incorrect because misrepresentation would require misleading communication, while the stated pressure itself is an objectivity issue. C is not the most direct classification because the facts specifically concern research influence.
Question 16 · Module 2
A research boutique accepts payment from an issuer to prepare a report. The analyst uses a reasonable process, reaches her own conclusion, and clearly discloses the issuer payment. Which statement is most accurate?
- AThe arrangement is not automatically prohibited if independence is preserved and the conflict is disclosed.
- BAny issuer payment automatically violates Standard I(B).
- CDisclosure alone permits the analyst to publish a conclusion she does not believe.
Check answer and explanation
Correct answer: A
Primary concept: Paid research is fact-sensitive; independence, reasonable basis, and disclosure matter.
Decisive fact: The analyst controls the conclusion and makes the economic relationship visible.
Explanation: A is correct because issuer-sponsored research is not automatically prohibited when the analyst preserves independent judgment, has a reasonable basis, and clearly discloses the payment. B is wrong because it treats every issuer payment as a per se violation despite the stated safeguards. C is wrong because disclosure identifies a conflict but cannot cure a conclusion the analyst does not believe or research that lacks support.
Question 17 · Module 2
An issuer invites an analyst to inspect a remote mine. No practical commercial route reaches the site, so the issuer pays for a modest charter flight and basic lodging. The analyst retains full editorial control. The analyst most likely:
- Aviolates Standard I(B) because issuer-paid travel is always prohibited.
- Bcomplies only if she promises a neutral rating before the trip.
- Cmay accept because the travel is practically necessary and modest, provided her judgment remains independent.
Check answer and explanation
Correct answer: C
Primary concept: Issuer-funded travel must be evaluated by necessity, modesty, and influence.
Decisive fact: No practical alternative exists, and the arrangement is limited to the site visit.
Explanation: C is correct because the remote site has no practical commercial access, the issuer pays only modest travel costs, and the analyst retains editorial control, so the necessary visit need not impair objectivity. A is wrong because issuer-funded travel is not automatically prohibited when necessity and modesty are established. B is wrong because promising any predetermined rating would surrender independent judgment rather than protect it.
Question 18 · Module 2
After a successful engagement, a client offers an analyst an expensive watch. The gift was not promised in advance. The analyst should most appropriately:
- Aaccept secretly because the work is complete.
- Bdisclose the gift promptly to the employer and follow applicable consent and gift policies.
- Caccept automatically because client gifts can never affect objectivity.
Check answer and explanation
Correct answer: B
Primary concept: Client gifts are not automatically prohibited, but transparency to the employer is required because they may influence future service.
Decisive fact: The valuable gift creates a potential influence even though it was unexpected.
Explanation: B is correct because the expensive unexpected gift from an existing client can influence future service, so prompt disclosure lets the employer evaluate it and enforce consent or gift-policy restrictions. A is wrong because secret acceptance prevents that conflict assessment. C is wrong because the client source and after-the-fact timing reduce some concern but do not make every valuable client gift harmless or exempt from employer controls.
Question 19 · Module 2
A wealth manager describes a risky structured product as "principal guaranteed" even though the guarantee applies only if a thinly capitalized affiliate remains solvent. This statement most likely violates:
- AStandard I(A) only, because all guarantees are illegal.
- BStandard I(C), because the description creates a misleading impression.
- Cno Standard, because a guarantee exists in the contract.
Check answer and explanation
Correct answer: B
Primary concept: Do not knowingly make false or misleading statements or omit decisive limitations.
Decisive fact: The description hides a material condition on the guarantee.
Explanation: B is correct because calling the product “principal guaranteed” without prominently explaining the affiliate's solvency condition creates a materially misleading overall impression under Standard I(C). A is wrong because the facts do not establish that every guarantee is illegal, so Standard I(A) is not the supported classification. C is wrong because a statement can be literally incomplete yet misleading when it omits the limitation most important to evaluating the guarantee.
Question 20 · Module 2
Priya uses a third-party forecasting model in a client report. She has not reviewed the model's assumptions, but labels the output as "our independently verified forecast." Priya most likely:
- Acomplies because a vendor supplied the model.
- Bcomplies if the forecast later proves accurate.
- Cviolates Standard I(C), and likely Standard V(A), because she misstates the review and fails to assess the basis.
Check answer and explanation
Correct answer: C
Primary concept: Outside inputs remain the professional's communication responsibility.
Decisive fact: Priya falsely claims verification without reviewing the assumptions.
Explanation: C is correct because Priya neither reviewed the model's assumptions nor independently verified it, yet expressly claims that verification; the statement is misleading and the forecast lacks a demonstrated reasonable basis. A is wrong because using a vendor does not transfer the analyst's responsibility to assess third-party work. B is wrong because a favorable later outcome cannot retroactively cure a false communication or an inadequate process at the time of publication.
Question 21 · Module 2
An analyst paraphrases a distinctive valuation framework developed by another researcher and presents it as her own. What should she have done?
- ACite only if she copied the exact words.
- BAttribute the distinctive idea to its source.
- CAvoid attribution because paraphrasing transfers ownership.
Check answer and explanation
Correct answer: B
Primary concept: Attribution applies to distinctive ideas, data, tables, models, and language.
Decisive fact: The intellectual contribution came from another identifiable researcher.
Explanation: B is correct because the identifiable researcher supplied the distinctive valuation framework, so the analyst must attribute that intellectual contribution even when she expresses it in different words. A is wrong because the misrepresentation and plagiarism duty extends beyond verbatim quotations to distinctive ideas, models, data, and methods. C is wrong because paraphrasing changes wording but does not transfer authorship or ownership of the underlying framework.
Question 22 · Module 2
A firm's report was developed by analysts acting within their employment. The firm later republishes the report under its own brand without naming every original team member. Assuming no misleading claim of outside authorship, the firm most likely:
- Aviolates Standard I(C) because every employee must be named forever.
- Bviolates Standard I(D) because a firm cannot own research.
- Cdoes not violate the Standards because work produced within employment is generally firm work.
Check answer and explanation
Correct answer: C
Primary concept: Employer-owned research has a different attribution boundary from outside work.
Decisive fact: The report was created within employment and is being used by the owning firm.
Explanation: C is correct because the analysts created the report within their employment, making it firm work that the firm may generally republish under its brand without naming every employee contributor. A is wrong because employee attribution is not perpetually required each time an employer reuses its own research. B is wrong because a firm can own work created within employment; distinct material originating outside the firm would still require appropriate attribution.
Question 23 · Module 2
An adviser discovers that yesterday's social-media post accidentally stated a bond yield of 8.2% instead of 6.2%. The adviser should most appropriately:
- Acorrect the error promptly and preserve an appropriate record of the correction.
- Bleave it unchanged because social-media posts are informal.
- Cdelete the account and say nothing further.
Check answer and explanation
Correct answer: A
Primary concept: Misleading errors in professional communications should be corrected promptly.
Decisive fact: The numerical error is material to an investment communication.
Explanation: A is correct because the yield error is material, so the adviser should correct the professional communication promptly and retain an auditable record of what changed. B is wrong because Standard I(C) applies to professional statements made through social media as well as formal reports. C is wrong because silently deleting the account may destroy relevant evidence and does not alert people who already relied on the erroneous 8.2% figure.
Question 24 · Module 2
A member submits fabricated taxi receipts to obtain reimbursement from her employer. The amount is small and unrelated to investment analysis. The conduct most likely:
- Adoes not violate the Standards because the amount is immaterial.
- Bviolates only Standard V(C), Record Retention.
- Cviolates Standard I(D) because intentional dishonesty reflects adversely on professional integrity.
Check answer and explanation
Correct answer: C
Primary concept: Do not engage in dishonest, fraudulent, or deceitful conduct that reflects adversely on professional integrity.
Decisive fact: The member intentionally submitted false evidence for personal gain.
Explanation: C is correct because fabricating receipts to obtain money from the employer is dishonest professional conduct within the employment relationship and therefore reflects adversely on the member's integrity under Standard I(D). A is wrong because intentional deceit does not become permissible when the amount is small. B is wrong because Standard V(C) concerns records supporting investment work, whereas the decisive issue here is fraudulent reimbursement conduct.
Question 25 · Module 2
Following a family emergency, a candidate misses two personal-loan payments but truthfully informs the lender and negotiates a repayment plan. There is no fraud and no effect on professional duties. The candidate most likely:
- Adoes not violate Standard I(D) on these facts.
- Bautomatically violates Standard I(D) because any default is misconduct.
- Cviolates Standard VII(B) because candidates may not borrow personally.
Check answer and explanation
Correct answer: A
Primary concept: Ordinary personal financial difficulty is not automatically professional misconduct.
Decisive fact: There is no dishonesty, fraud, or adverse professional effect.
Explanation: A is correct because an honest temporary payment difficulty, transparently addressed with the lender, involves no fraud, deceit, professional activity, or adverse effect on professional duties on the stated facts. B is wrong because Standard I(D) does not classify every personal default as misconduct. C is wrong because Standard VII(B) does not prohibit candidates from borrowing; a fraudulent application or professional nexus could change the analysis, but neither is present.
Question 26 · Module 2
A manager with no experience in private infrastructure is asked to approve a complex fund within two days. What is the manager's most appropriate response?
- AApprove it because seniority establishes competence.
- BApprove it if a vendor supplies a favorable score.
- CIdentify the competence gap and obtain training, qualified support, or more time before acting.
Check answer and explanation
Correct answer: C
Primary concept: Act with and maintain the competence necessary to fulfill professional responsibilities.
Decisive fact: The manager lacks role-relevant knowledge for a material decision.
Explanation: C is correct because Standard I(E) requires the competence necessary for the assigned responsibility before the manager approves the complex fund; obtaining training, qualified support, or adequate review time directly addresses the identified gap. A is wrong because seniority is not evidence of role-specific knowledge or skill. B is wrong because a vendor score cannot transfer the manager's responsibility or show that the manager can evaluate the vendor's methods and conclusion.
Question 27 · Module 2
An analyst performs diligent, role-appropriate research and reaches a reasonable conclusion, but the investment later loses money. Under Standard I(E), the loss:
- Aproves the analyst lacked competence.
- Bdoes not by itself prove a competence violation.
- Cproves a violation unless the client signed a risk waiver.
Check answer and explanation
Correct answer: B
Primary concept: Competence is evaluated through role-appropriate knowledge and process, not outcome alone.
Decisive fact: The analyst used a diligent and reasonable process before the adverse result.
Explanation: B is correct because an investment loss can occur despite competent work. A is incorrect because it uses hindsight and the outcome as the sole test of professional competence. C is wrong because a client waiver neither establishes competence nor excuses its absence.
Question 28 · Module 2
A supervisor deploys an artificial-intelligence research system without understanding its inputs, validation, or failure modes. The vendor says the software is "fully responsible" for every output. The supervisor most likely:
- Acomplies because the vendor accepted responsibility.
- Bcomplies if no client has complained.
- Cviolates professional duties because a tool cannot absorb the supervisor's competence and oversight responsibilities.
Check answer and explanation
Correct answer: C
Primary concept: Technology does not own professional judgment or supervisory accountability.
Decisive fact: The supervisor cannot evaluate the system but allows staff and clients to rely on it.
Explanation: C is correct because the supervisor deploys a system whose inputs, validation, and failure modes he cannot evaluate, so he cannot exercise the role-specific competence and oversight required for professional reliance. A is wrong because vendor language cannot transfer the member's ethical and supervisory responsibilities to software or its seller. B is wrong because the absence of complaints says nothing about whether the system was understood, validated, or monitored competently.
Question 29 · Module 2
Before distributing a digital security in three countries, a product specialist should first:
- Aidentify which laws and professional requirements govern the design, offering, and distribution activities.
- Bassume the law of the firm's headquarters controls every activity.
- Cuse the least strict rule to improve consistency across markets.
Check answer and explanation
Correct answer: A
Primary concept: Applicability comes before comparison of strictness.
Decisive fact: Different activities and distribution locations may trigger different laws.
Explanation: A is correct because the specialist must first identify which jurisdictions and activities govern the design, offering, and distribution before comparing legal and professional requirements. B is wrong because headquarters law does not automatically displace rules applying where securities are offered or investors are located. C is wrong because a professional cannot select the least strict rule for convenience; once applicability is established, the controlling and stricter duties must be followed.
Question 30 · Module 2
A fund factsheet displays five years of strong gross returns in large type and places mandatory fees and major liquidity restrictions in barely visible text. The factsheet most likely:
- Acomplies because all information appears somewhere.
- Bviolates only if the gross returns are mathematically wrong.
- Cviolates Standard I(C) because true statements can create a misleading overall impression through omission and presentation.
Check answer and explanation
Correct answer: C
Primary concept: Communication must not mislead through selective emphasis or material omission.
Decisive fact: The design hides costs and restrictions needed to interpret the return claim.
Explanation: C is correct because prominent gross returns paired with obscured recurring costs and liquidity limits create a misleading overall impression even if each isolated figure is true. A is wrong because merely placing information somewhere in a factsheet does not make a material qualification clear or effective. B is wrong because mathematical accuracy of the return series does not cure selective emphasis or omissions that prevent investors from understanding the economic result.
Question 31 · Module 2
After unsuccessfully trying to stop an employer's violation, a member removes her name from the work, seeks reassignment, and documents the escalation. Standard I(A) generally:
- Arequires dissociation but does not always require external reporting unless applicable law imposes it.
- Balways requires an immediate public accusation.
- Cpermits continued participation if the member privately disagrees.
Check answer and explanation
Correct answer: A
Primary concept: Dissociation is required when necessary; external reporting depends on applicable requirements and circumstances.
Decisive fact: The member has taken concrete steps to end participation.
Explanation: A is correct because, after reasonable efforts to stop the violation fail, the member must end her involvement through dissociation; whether she must report externally depends on applicable law and the circumstances. B is wrong because Standard I(A) does not impose a universal duty to make an immediate public accusation. C is wrong because privately disagreeing while continuing to assist the unlawful work would still amount to knowing participation.
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Module 3
Standard II: Integrity of Capital Markets
Questions 32-39 · 8 questions
Question 32 · Module 3
For information to trigger Standard II(A)'s trading prohibition, it must be:
- Aboth material and nonpublic.
- Beither material or nonpublic.
- Cconfidential to the analyst, even if already broadly public.
Check answer and explanation
Correct answer: A
Primary concept: Do not act or cause others to act on material nonpublic information.
Decisive fact: Both materiality and nonpublic status are required.
Explanation: A is correct because Standard II(A)'s prohibition applies only when the information is both material to a reasonable investor and not yet public; either element missing defeats that specific prohibition. B is wrong because material public information and immaterial nonpublic information do not independently satisfy both conditions. C is wrong because information already broadly available to the market remains public even if an analyst later receives the same fact privately.
Question 33 · Module 3
An analyst combines public filings, public satellite images, and several nonmaterial observations from suppliers to conclude that demand is weakening. Trading on the conclusion is most likely:
- Aprohibited because any nonpublic input makes the conclusion illegal.
- Bpermissible under the mosaic theory if no input is material nonpublic information and the analysis is lawful.
- Cpermissible only if the issuer approves the conclusion.
Check answer and explanation
Correct answer: B
Primary concept: Material public information plus nonmaterial nonpublic information may support a lawful analytical conclusion.
Decisive fact: None of the nonpublic pieces is material by itself.
Explanation: B is correct because the conclusion comes from lawful analysis of public material plus supplier observations that are individually nonmaterial, which is the permitted mosaic-theory pattern. A is wrong because Standard II(A) does not prohibit every nonpublic detail; it prohibits acting on information that is both material and nonpublic. C is wrong because issuer approval is unnecessary and cannot replace the actual tests of materiality, public status, and lawful acquisition.
Question 34 · Module 3
An issuer tells six invited analysts about an unannounced major acquisition and asks them not to trade. The information becomes public when:
- Ait is broadly available to the investing marketplace, not merely shared with the selected analysts.
- Bthe sixth analyst hears it.
- Cone analyst decides it is credible.
Check answer and explanation
Correct answer: A
Primary concept: Selective disclosure to a small group is not broad public dissemination.
Decisive fact: Access remains limited to invited analysts.
Explanation: A is correct because information becomes public only when it is broadly disseminated or otherwise available to the investing marketplace; selective disclosure to six analysts remains nonpublic. B is wrong because the number of invited analysts does not turn a closed briefing into public availability. C is wrong because one analyst's belief that the information is credible addresses reliability, not public status; trading or causing others to trade remains prohibited until broad dissemination.
Question 35 · Module 3
A physician tells an analyst that enrollment in a major clinical trial has been halted for safety reasons. The news is unannounced and likely to affect the issuer's value. The analyst buys put options. The analyst most likely:
- Acomplies because options are not the issuer's shares.
- Bviolates Standard II(A) because the information is material and nonpublic and the instrument does not create a safe harbor.
- Ccomplies because the physician is not an issuer employee.
Check answer and explanation
Correct answer: B
Primary concept: Instrument and source do not remove material nonpublic status.
Decisive fact: The analyst trades an economically linked instrument on specific, price-sensitive, unannounced information.
Explanation: B is correct because the halted clinical trial is specific, unannounced, and likely price-sensitive, and buying put options acts directly on that material nonpublic advantage. A is wrong because Standard II(A) applies to economically linked derivatives as well as purchases or sales of the issuer's shares. C is wrong because materiality and nonpublic status depend on the information, not whether its source is an issuer employee.
Question 36 · Module 3
A firm uses expert-network calls. It screens experts, prohibits disclosure of confidential information, trains analysts, and documents calls. The arrangement is most likely:
- Apermissible if analysts continue to assess whether information is material and nonpublic.
- Bautomatically prohibited because experts always possess inside information.
- Cpermissible because written controls make every received fact public.
Check answer and explanation
Correct answer: A
Primary concept: Expert networks require controls and continuing professional judgment.
Decisive fact: The firm manages the risk but does not assume the controls create a safe harbor.
Explanation: A is correct because screening, training, call controls, and documentation can support legitimate expert-network research, but each analyst must still judge whether a specific disclosure is material and nonpublic. B is wrong because experts do not invariably possess or disclose inside information, so the channel is not automatically prohibited. C is wrong because written controls reduce risk but cannot convert confidential price-sensitive facts into public information or create a safe harbor.
Question 37 · Module 3
A trader spreads a false rumor about a bank's solvency to move its share price and profit from a short position. The trader most likely:
- Acomplies if the rumor is framed as an opinion.
- Bviolates only Standard II(A).
- Cviolates Standard II(B) because the conduct is intended to distort market beliefs and price formation.
Check answer and explanation
Correct answer: C
Primary concept: Do not engage in practices that distort prices or volume with intent to mislead market participants.
Decisive fact: The trader knowingly creates false information to move the market.
Explanation: C is correct because knowingly spreading a false solvency rumor to move the bank's share price and profit from a short position is information-based market manipulation under Standard II(B). A is wrong because calling a fabricated statement an opinion does not remove its deceptive purpose. B is wrong because the facts do not establish possession of material nonpublic information; they establish creation and dissemination of false information to distort price formation.
Question 38 · Module 3
Which conduct is the clearest example of transaction-based manipulation?
- AEntering offsetting wash trades to create the appearance of active demand.
- BPublishing a well-supported valuation that differs from consensus.
- CSelling a genuinely overvalued security in a large order.
Check answer and explanation
Correct answer: A
Primary concept: Transaction-based schemes create deceptive prices, volume, or trading signals.
Decisive fact: Wash trades lack genuine economic purpose and manufacture activity.
Explanation: A is correct because offsetting wash trades create artificial volume without genuine economic substance and are designed to mislead observers about market demand, making them transaction-based manipulation. B is wrong because publishing a well-supported valuation is legitimate research even when it affects price. C is wrong because a large sale based on a genuine overvaluation view has economic purpose and is not manipulative absent deceptive orders or intent.
Question 39 · Module 3
A fund believes a small issuer is materially overvalued. It builds and publicly discloses a large short position, then sells additional shares as part of a genuine investment strategy. The position affects price. Without deceptive orders or false statements, the fund most likely:
- Aviolates Standard II(B) because any large position is manipulative.
- Bviolates Standard II(B) because profit is intended.
- Cdoes not necessarily violate Standard II(B), because price impact and profit do not replace the need for deceptive intent or conduct.
Check answer and explanation
Correct answer: C
Primary concept: Legitimate market activity can have economic purpose and price impact.
Decisive fact: The transactions express a genuine investment view without deceptive signals.
Explanation: C is correct because the large short position expresses a genuine, disclosed investment view and the facts contain no deceptive orders, false information, or intent to create an artificial signal. A is wrong because position size and resulting price impact do not by themselves establish manipulation. B is wrong because an intent to profit is ordinary in investing; Standard II(B) instead requires deceptive conduct or manipulative intent, which the scenario expressly withholds.
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Module 4
Standard III: Duties to Clients
Questions 40-55 · 16 questions
Question 40 · Module 4
A corporation's chief executive pressures the manager of its pension plan to buy bonds issued by the corporation, even though the bonds are unsuitable for the plan. Under Standard III(A), the manager's client is most appropriately identified as:
- Athe chief executive who gives instructions.
- Bthe pension plan and its beneficiaries, as defined by the governing documents.
- Cthe corporation's bondholders.
Check answer and explanation
Correct answer: B
Primary concept: Identify the actual client before acting and place that client's interests first.
Decisive fact: The manager was engaged to serve the pension assets and beneficiaries under the plan documents.
Explanation: B is correct because the governing pension documents establish that the manager serves the plan and its beneficiaries, whose suitability and loyalty interests control the investment decision. A is wrong because the chief executive may communicate instructions but is not thereby the client entitled to redirect plan assets for the corporation's benefit. C is wrong because corporate bondholders are separate stakeholders and do not own the manager's duty under the pension mandate.
Question 41 · Module 4
A manager directs client brokerage to a dealer that provides the manager with office furniture. The arrangement provides no client benefit. The manager most likely:
- Aviolates Standard III(A) because client brokerage must be used for client benefit.
- Bcomplies if the dealer's execution price is average.
- Ccomplies because brokerage commissions belong to the manager after execution.
Check answer and explanation
Correct answer: A
Primary concept: Client brokerage is a client asset and must serve the client.
Decisive fact: The benefit is ordinary firm property rather than research or execution value for clients.
Explanation: A is correct because client brokerage is a client asset and the office furniture benefits the manager or firm rather than improving research or execution for the client. B is wrong because an acceptable execution price does not authorize using commission value for a nonclient purpose; loyalty governs the whole arrangement. C is wrong because brokerage commissions never become the manager's personal property merely because a trade has been executed.
Question 42 · Module 4
An adviser recommends a ten-year private fund to a client with a documented need for monthly liquidity. The fund may be attractive in isolation but is inconsistent with the client's overall circumstances. The recommendation most likely:
- Acomplies because the fund has a high expected return.
- Bcomplies if the client signs a general risk disclosure.
- Cviolates Standard III(C) because suitability is evaluated in the context of the client and portfolio.
Check answer and explanation
Correct answer: C
Primary concept: In an advisory relationship, investigate the client's circumstances and judge suitability in total-portfolio context.
Decisive fact: The investment's illiquidity conflicts with a known monthly cash need.
Explanation: C is correct because the ten-year lockup directly conflicts with the client's documented monthly liquidity need, so the recommendation is unsuitable in the context of the client's circumstances and total portfolio. A is wrong because a high expected return cannot override a binding liquidity constraint. B is wrong because a general risk disclosure may inform the client but does not replace the adviser's obligation to determine suitability for the mandate.
Question 43 · Module 4
A conservative client gives an unsolicited instruction to place half of a managed portfolio in one speculative security, contrary to the written investment policy. The adviser should most appropriately:
- Aexecute automatically because the instruction is unsolicited.
- Bexplain the conflict, assess its portfolio impact, and decline or move the trade outside the managed mandate if the material conflict remains.
- Cchange the policy after executing the order.
Check answer and explanation
Correct answer: B
Primary concept: Standard III(C) requires recommendations and actions to be consistent with the stated objectives and constraints of the portfolio; an unsolicited instruction is not an automatic exemption from that duty.
Decisive fact: The order would materially transform the managed portfolio and violate its policy.
Explanation: B is correct because investing half of this managed conservative portfolio in one speculative security would conflict materially with its stated objectives and constraints; the adviser must discuss and assess the instruction before declining it, updating the policy, or arranging execution outside the managed mandate as appropriate. A is wrong because client initiation does not create an automatic suitability safe harbor. C is wrong because changing the policy after execution would be an impermissible post hoc cure rather than a documented decision made before the managed action.
Question 44 · Module 4
A manager runs a "short-duration government bond" mandate. Without changing the governing agreement, she recommends a concentrated position in long-duration high-yield bonds because she expects a rally. Under Standard III(C), the manager most likely:
- Acomplies because the client owns the assets.
- Bcomplies if the rally occurs.
- Cviolates Standard III(C) because recommendations and actions must remain consistent with the mandate's objectives and constraints.
Check answer and explanation
Correct answer: C
Primary concept: A manager of a portfolio with a stated mandate, strategy, or style must make recommendations and take actions that are consistent with the stated objectives and constraints of the portfolio.
Decisive fact: The proposed assets contradict both duration and credit boundaries.
Explanation: C is correct because both the long duration and high credit risk fall outside the portfolio's stated government-bond mandate, and the governing agreement has not been amended before the recommendation. A is wrong because client ownership of the assets does not authorize the manager to disregard agreed objectives and constraints. B is wrong because a later rally would not cure a suitability and mandate violation that existed when the action was proposed.
Question 45 · Module 4
A firm emails a material recommendation to all affected clients through the same distribution system. Some clients receive it seconds later because of network latency. The firm most likely:
- Acomplies with Standard III(B) because fair dealing requires a fair process, not perfect simultaneity.
- Bviolates Standard III(B) because every client must receive information at the identical millisecond.
- Ccomplies only if the recommendation is unprofitable.
Check answer and explanation
Correct answer: A
Primary concept: Deal fairly and objectively with clients; fair does not mean mechanically identical.
Decisive fact: The firm used one neutral distribution process for all affected clients.
Explanation: A is correct because the firm used the same neutral dissemination system for every affected client; unavoidable seconds of network latency do not defeat an otherwise fair process. B is wrong because Standard III(B) requires fair and objective dealing, not delivery to every device at the identical millisecond. C is wrong because compliance is assessed from the dissemination process and opportunity to act, not whether the recommendation later earns or loses money.
Question 46 · Module 4
A firm offers premium clients more frequent portfolio meetings under service tiers and fees disclosed in advance and available to any client who elects them. Every affected client receives material recommendations through the same fair distribution process. The arrangement most likely:
- Aviolates Standard III(B) because all services must be identical.
- Bcomplies because disclosed service differences can coexist with fair access to material recommendations.
- Cviolates Standard III(A) because premium fees are always disloyal.
Check answer and explanation
Correct answer: B
Primary concept: Disclosed service tiers may differ, while material investment opportunities must still be handled fairly.
Decisive fact: The premium tier is openly available, and the difference concerns meeting frequency rather than selective access to the material recommendation.
Explanation: B is correct because differentiated meeting frequency may be fair when the tier is disclosed in advance, available to all clients on the same terms, and does not delay anyone's access to material recommendations. A is wrong because Standard III(B) requires fair dealing rather than identical service packages. C is wrong because charging a disclosed fee for genuinely additional service is not inherently disloyal when the firm still protects every client's core interests.
Question 47 · Module 4
A manager's sibling has an ordinary fee-paying account at the manager's firm. The manager has no beneficial interest in it. When allocating an oversubscribed offering, the manager should:
- Aexclude the account solely because it belongs to family.
- Btreat it fairly under the same objective allocation process as comparable client accounts.
- Callocate to it first to avoid appearing biased against family.
Check answer and explanation
Correct answer: B
Primary concept: Family accounts require classification by beneficial ownership and client status.
Decisive fact: The manager has no beneficial interest, and the account is a genuine fee-paying client.
Explanation: B is correct because the sibling's account is an ordinary fee-paying client account in which the manager has no beneficial interest, so it should participate under the same objective allocation policy as comparable clients. A is wrong because family relationship alone does not justify excluding a genuine client. C is wrong because allocating to the account first would create favoritism; if the manager had beneficial ownership, separate transaction-priority controls would apply.
Question 48 · Module 4
A portfolio manager waits until an initial public offering rises sharply, then allocates the largest positions to favored clients. The manager most likely violates Standard III(B) because:
- Aallocation procedures should be objective and established before the result is known.
- Ball oversubscribed offerings must be divided into identical share amounts.
- Cprofitable offerings may never be allocated to clients.
Check answer and explanation
Correct answer: A
Primary concept: Use written, consistently applied allocation procedures before outcomes are known.
Decisive fact: The manager uses hindsight to favor selected clients.
Explanation: A is correct because waiting to see the IPO's gain and then favoring selected accounts substitutes hindsight and favoritism for an objective allocation policy established before the outcome. B is wrong because fair allocation need not give identical share counts; account size, suitability, and documented policy can justify proportional differences. C is wrong because profitable offerings may be allocated to suitable client accounts—the violation is the biased method, not client participation.
Question 49 · Module 4
A performance presentation excludes every account that terminated after a period of poor results but retains accounts that terminated after strong results. The presentation most likely:
- Aviolates Standard III(D) because selective exclusion creates survivor bias.
- Bcomplies if all remaining return calculations are accurate.
- Ccomplies because terminated accounts never belong in historical performance.
Check answer and explanation
Correct answer: A
Primary concept: Make reasonable efforts to present performance fairly, accurately, and completely.
Decisive fact: The manager selects accounts based on whether their results improve the presentation.
Explanation: A is correct because excluding every poor terminated account while retaining strong terminated accounts selects results by outcome and creates survivor bias, making the presentation unfair under Standard III(D). B is wrong because accurate calculations for the remaining accounts do not cure the biased population. C is wrong because termination alone does not erase relevant historical performance; inclusion must follow an appropriate methodology applied consistently to winners and losers.
Question 50 · Module 4
A one-page performance summary uses a suitable composite, states that returns are net of fees, identifies the benchmark and period, and directs readers to fuller required information. The summary most likely:
- Aviolates Standard III(D) because every presentation must contain every possible detail.
- Bcomplies only if the strategy outperformed.
- Cmay comply because a short presentation can still be fair, accurate, and complete for its purpose.
Check answer and explanation
Correct answer: C
Primary concept: Completeness is contextual and does not require maximum length.
Decisive fact: The summary includes the information needed to interpret the result and offers fuller detail.
Explanation: C is correct because a concise presentation may be fair and complete for its purpose when it identifies the composite, fee basis, benchmark, and period and gives readers access to fuller required information. A is wrong because Standard III(D) does not require every possible detail on a single page; it requires a presentation that is not misleading. B is wrong because compliance depends on fair communication, not whether the strategy happened to outperform.
Question 51 · Module 4
A manager accurately computes the average return of the accounts still open at year-end but omits three accounts closed after severe losses. She labels the figure "representative performance." The claim most likely:
- Acomplies because the arithmetic is correct.
- Bcomplies if the closed accounts are no longer clients.
- Cviolates Standard III(D) because accurate arithmetic can support a misleading selection.
Check answer and explanation
Correct answer: C
Primary concept: Fair presentation requires more than correct calculation.
Decisive fact: Loss accounts are omitted while the result is described as representative.
Explanation: C is correct because excluding only the accounts that closed after severe losses biases the selected population and makes the label “representative performance” misleading despite accurate averaging. A is wrong because correct arithmetic cannot cure a deliberately unrepresentative input set. B is wrong because an account's later termination does not erase its relevant historical return; inclusion must follow a consistent, fair methodology rather than the result achieved.
Question 52 · Module 4
Standard III(E)'s confidentiality duty most directly covers information about:
- Acurrent, former, and prospective clients.
- Bcurrent clients only.
- Cclients only until the information becomes inconvenient to retain.
Check answer and explanation
Correct answer: A
Primary concept: Preserve confidential information across the full client lifecycle.
Decisive fact: The duty is not limited to active relationships.
Explanation: A is correct because Standard III(E) protects confidential information obtained from prospective clients and continues to protect former clients after the relationship ends, as well as covering current clients. B is wrong because ending or not yet starting a formal engagement does not remove the confidentiality duty. C is wrong because inconvenience creates no exception; disclosure requires a recognized basis such as client permission, illegal client activity, or applicable law.
Question 53 · Module 4
An adviser discovers evidence that a client is using the account for illegal activity. Applicable law permits disclosure to the competent authority. The adviser most likely:
- Amust preserve secrecy in every circumstance.
- Bmay disclose as permitted by law under the illegal-activity exception.
- Cmay publish the information to all clients.
Check answer and explanation
Correct answer: B
Primary concept: Confidentiality exceptions are narrow and depend on authority.
Decisive fact: The information concerns illegal activity, and law permits disclosure to the proper authority.
Explanation: B is correct because Standard III(E) expressly permits disclosure when client information concerns illegal activity and applicable law allows reporting to the competent authority. A is wrong because confidentiality is not absolute under a recognized exception. C is wrong because the exception permits a controlled disclosure for a proper purpose, not unrestricted publication to unrelated clients.
Question 54 · Module 4
A university endowment faces a liquidity crisis. An adviser wants to tell a wealthy donor about the problem because the donor might help. The endowment has not consented, no law requires disclosure, and no illegal activity is involved. The adviser should:
- Adisclose because the donor is a stakeholder.
- Bdisclose only if the donor promises confidentiality.
- Cpreserve confidentiality because good intentions do not create authority to disclose.
Check answer and explanation
Correct answer: C
Primary concept: Helpful purpose is not a substitute for client consent or legal authority.
Decisive fact: None of the recognized exceptions applies.
Explanation: C is correct because none of Standard III(E)'s recognized bases for disclosure—client permission, applicable legal authority, or illegal client activity—is present, so the endowment's information remains confidential. A is wrong because a donor's stakeholder status and helpful purpose do not authorize disclosure. B is wrong because the proposed recipient's promise of secrecy cannot substitute for permission from the client or a controlling legal duty.
Question 55 · Module 4
Which action best reflects Standard III(E) in a modern digital environment?
- ASending client files through any convenient personal account if the adviser trusts the recipient.
- BKeeping every client file indefinitely on an unencrypted personal device.
- CUsing approved secure channels, limiting access, following retention rules, and escalating suspected breaches.
Check answer and explanation
Correct answer: C
Primary concept: A duty not to disclose includes a duty to handle information carefully.
Decisive fact: Confidentiality risks arise from storage, transfer, access, and disposal as well as speech.
Explanation: C is correct because secure approved channels, access limits, retention controls, and prompt escalation reduce foreseeable threats to client confidentiality. A is wrong because a trusted recipient does not make an unapproved personal account secure or auditable. B is wrong because indefinite storage on an unencrypted personal device creates unnecessary exposure and may conflict with retention and deletion rules.
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Module 5
Standard IV: Duties to Employers
Questions 56-65 · 10 questions
Question 56 · Module 5
While still employed, an analyst plans to open an independent advisory firm after resigning. Which action is most likely permissible without employer consent?
- ASoliciting the employer's current clients before departure.
- BRegistering a future company and preparing personal business plans on her own time without using employer resources.
- CCopying the employer's client list to a personal drive.
Check answer and explanation
Correct answer: B
Primary concept: Preparation for future competition may be permissible; active competition and misappropriation are not.
Decisive fact: The preparation does not use employer property or interfere with current duties.
Explanation: B is correct because an employee may make limited preparations for future independent work on personal time without competing or misusing employer resources. A is wrong because soliciting current clients before departure is active competition. C is wrong because a confidential client list is employer property and may not be copied for the future venture without permission.
Question 57 · Module 5
Before resigning, a relationship manager emails the employer's clients from a personal account and asks them to move assets to his future firm. The manager most likely:
- Acomplies because the future firm is not yet operating.
- Bcomplies if he uses no employer device.
- Cviolates Standard IV(A) because he is soliciting clients and competing while still employed.
Check answer and explanation
Correct answer: C
Primary concept: Loyalty continues until the employment relationship actually ends.
Decisive fact: The manager actively solicits employer clients before departure.
Explanation: C is correct because directly soliciting the employer's current clients for a future competing firm is active competition while the employment duty of loyalty remains in force. A is wrong because the future firm's operating status does not change the manager's present solicitation. B is wrong because using a personal email account may avoid an employer device, but it does not convert disloyal competitive conduct into permissible preparation for departure.
Question 58 · Module 5
After resigning, which item may a former analyst generally use, absent a contrary valid agreement or law?
- AGeneral skills and knowledge retained through experience.
- BCopies of employer research files saved on a personal laptop.
- CThe employer's confidential client contact list.
Check answer and explanation
Correct answer: A
Primary concept: Knowledge and property diverge after departure.
Decisive fact: General experience is not the employer's confidential record or physical property.
Explanation: A is correct because a former employee may generally apply experience, judgment, and general skills developed during employment. B is wrong because saved research files remain employer work product and may contain confidential information. C is wrong because a confidential client list is not personal knowledge that can be appropriated after resignation; authorization or a valid separate source would be required.
Question 59 · Module 5
A client offers a portfolio manager a side bonus equal to 10% of returns above a target. The arrangement could conflict with the employer's interests. Before accepting, the manager should obtain:
- Aoral approval from the client only.
- Bwritten consent from all involved parties after disclosing the terms.
- Capproval from a colleague who does not supervise the account.
Check answer and explanation
Correct answer: B
Primary concept: Conflicting additional compensation requires written consent from all parties involved.
Decisive fact: The payment may compete with or create a conflict with the employer's compensation arrangement.
Explanation: B is correct because the side bonus may alter incentives and therefore requires full disclosure and written consent from all involved parties before acceptance. A is wrong because client approval alone omits the employer and is not in the required written form. C is wrong because a nonsupervisory colleague cannot consent for the employer or resolve the conflict.
Question 60 · Module 5
A pension client unexpectedly pays for a research team's modest working lunch after a routine quarterly review. No reward had been discussed, and the firm's hospitality policy sets a value threshold for reporting. The manager should most appropriately:
- Aclassify the lunch automatically as a promised performance bonus and seek retroactive consent for additional compensation.
- Bdivide the bill among the team members so that the employer's hospitality policy no longer applies.
- Cdocument the value and circumstances and make any disclosure or obtain any approval required by the employer's policy.
Check answer and explanation
Correct answer: C
Primary concept: Timing and purpose distinguish a promised performance reward from an unexpected thank-you gift.
Decisive fact: The hospitality was spontaneous rather than contracted compensation, but its value and circumstances still fall within the employer's conflict controls.
Explanation: C is correct because the manager should record what occurred and apply the employer's stated hospitality threshold, allowing the firm to assess any influence on future service. A is incorrect because an unplanned working lunch is not automatically a prearranged performance-reward contract requiring retroactive treatment as additional compensation. B is incorrect because splitting the economic value among recipients does not erase the source, purpose, or reporting requirements of the hospitality.
Question 61 · Module 5
A head of research tells a deputy, "You are responsible for compliance now," but never reviews the firm's controls or follows up on repeated red flags. Under Standard IV(C), the head most likely:
- Acomplies because delegation transfers all responsibility.
- Bcomplies if the deputy is experienced.
- Cviolates because supervisors retain responsibility to make reasonable efforts to prevent and detect violations.
Check answer and explanation
Correct answer: C
Primary concept: Supervisors own the compliance effort within their authority.
Decisive fact: The head neither evaluates the control system nor responds to warning signs.
Explanation: C is correct because the head retains responsibility to assess whether compliance procedures are adequate, monitor their operation, and respond to repeated red flags even after assigning daily tasks to a deputy. A is wrong because delegation does not transfer the supervisor's Standard IV(C) duty. B is wrong because the deputy's experience may support the system but cannot excuse the head's failure to review controls or follow up on warnings.
Question 62 · Module 5
A director is asked to supervise a new trading unit, but the firm has no workable procedures for monitoring personal trading. Senior management refuses to add controls. The director should most appropriately:
- Adecline the role or continue only after a reasonable system is established.
- Baccept because responsibility belongs to senior management alone.
- Caccept and rely on employees to report themselves voluntarily.
Check answer and explanation
Correct answer: A
Primary concept: Supervisory authority must be supported by a reasonable compliance system.
Decisive fact: The director knows a material control gap exists and cannot correct it.
Explanation: A is correct because accepting supervisory authority without a workable personal-trading control system would leave the director unable to make the reasonable preventive and detective efforts Standard IV(C) requires. B is wrong because senior management's refusal does not eliminate the director's own duty after she accepts the role. C is wrong because voluntary self-reporting alone is not a reasonable substitute for tailored procedures, monitoring, and escalation.
Question 63 · Module 5
A supervisor notices that one analyst repeatedly changes model inputs after learning the desired recommendation. What should the supervisor most appropriately do?
- AIgnore it until a client complains.
- BWait for proof of a completed violation before asking questions.
- CInvestigate promptly, limit affected activity while facts are assessed, and escalate or correct as appropriate.
Check answer and explanation
Correct answer: C
Primary concept: Red flags trigger investigation and reasonable restraint.
Decisive fact: Repeated outcome-driven changes are credible warning signs.
Explanation: C is correct because repeated outcome-driven model changes are concrete red flags, requiring prompt inquiry, proportionate restraint of affected work, and escalation or correction based on the findings. A is wrong because a supervisor need not wait for a client complaint before addressing credible warning signs. B is wrong because reasonable supervision is preventive as well as detective; final proof of a completed violation is not a prerequisite to investigate.
Question 64 · Module 5
An employee circumvents a well-designed compliance system through an unprecedented deception. The supervisor had implemented tailored policies, training, monitoring, and documented review. The supervisor most likely:
- Adoes not automatically violate Standard IV(C), because the duty is one of reasonable efforts rather than guaranteed prevention.
- Bautomatically violates whenever any subordinate violates.
- Ccomplies only if the employee's conduct was profitable for clients.
Check answer and explanation
Correct answer: A
Primary concept: Supervisory responsibility is tested by the reasonableness of controls and response, not strict liability.
Decisive fact: The system was reasonably designed and implemented before an extraordinary evasion.
Explanation: A is correct because Standard IV(C) requires reasonable supervisory efforts, not a guarantee that a well-designed and implemented system will prevent every unprecedented deception. B is wrong because a subordinate's violation does not create strict liability when the supervisor's controls and response were reasonable. C is wrong because client profitability neither excuses the employee's conduct nor determines whether the supervisor satisfied the required compliance process.
Question 65 · Module 5
An employee reports the employer's deliberate client fraud to the competent regulator after internal escalation fails. The employee acts to protect clients and does not seek personal advantage. Under Standard IV(A), the reporting most likely:
- Aalways violates loyalty because external reporting harms the employer.
- Bis permitted only after the employee resigns.
- Cmay be consistent with loyalty because client and market integrity can take priority over employer interests.
Check answer and explanation
Correct answer: C
Primary concept: Loyalty to an employer does not require silence that facilitates client or market harm.
Decisive fact: The report protects clients after internal efforts fail and is not motivated by personal gain.
Explanation: C is correct because loyalty does not require silence about deliberate fraud when reasonable reporting is undertaken to protect clients and market integrity. A is wrong because employer interests are not absolute and cannot compel participation in wrongdoing. B is wrong because resignation is not a universal condition for protected or otherwise appropriate reporting, although legal advice may be necessary.
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Module 6
Standard V: Investment Analysis, Recommendations, and Actions
Questions 66-77 · 12 questions
Question 66 · Module 6
A firm's approved data vendor begins issuing credit ratings with unexplained methodology changes and repeated calculation errors. An analyst continues to rely on the ratings solely because the vendor remains approved. The analyst most likely:
- Acomplies because firm approval transfers responsibility.
- Bviolates Standard V(A) by ignoring specific evidence that the source may no longer be reliable.
- Cviolates only if an investment loses money.
Check answer and explanation
Correct answer: B
Primary concept: Exercise diligence, independence, and thoroughness, including review of third-party sources.
Decisive fact: New red flags undermine the earlier basis for reliance.
Explanation: B is correct because the new methodological opacity and repeated errors are warning signs that require the analyst to re-evaluate the vendor and the reasonable basis for reliance. A is wrong because prior firm approval is not permanent proof of quality. C is wrong because Standard V(A) assesses diligence when the research is used; a client loss is not required to establish a deficient process.
Question 67 · Module 6
A quantitative analyst designs a model used for client portfolios. Which responsibility is most appropriate for the model developer?
- AAccept every input selected by users without review.
- BFocus only on the code's speed because users own all validation.
- CDesign and validate the model, document assumptions and limitations, and monitor its behavior over time.
Check answer and explanation
Correct answer: C
Primary concept: Model builders and model users have different but complementary burdens.
Decisive fact: The developer controls design, testing, documentation, and maintenance.
Explanation: C is correct because the developer controls the model's design and therefore must test it, document assumptions and limitations, and monitor whether it continues to behave as intended. A is wrong because accepting every user-selected input without validation can embed foreseeable errors and defeats the developer's quality-control role. B is wrong because code speed alone does not establish a reasonable model; users have application duties, but those duties do not erase the builder's own responsibilities.
Question 68 · Module 6
A well-supported recommendation loses 18% after an unforeseeable macroeconomic event. Which statement is most accurate under Standard V(A)?
- AThe loss alone does not establish a violation; the basis is evaluated at the time of the decision.
- BEvery losing recommendation lacks a reasonable basis.
- CA client disclaimer automatically proves the basis was reasonable.
Check answer and explanation
Correct answer: A
Primary concept: Process quality and investment outcome are different questions.
Decisive fact: The recommendation was supported when made, and the later event was unforeseeable.
Explanation: A is correct because reasonable basis is judged from the diligence, evidence, and analysis available when the recommendation was made, not from a later unforeseeable return. B is wrong because losses can occur despite a sound process. C is wrong because a disclaimer may communicate risk but cannot manufacture research, independence, or thoroughness that the analyst did not have.
Question 69 · Module 6
Before onboarding clients to an automated advisory platform, the firm most directly must explain:
- Aonly the platform's historical return.
- Bonly the algorithm's programming language.
- Cthe nature of the services, important boundaries, and costs borne by clients.
Check answer and explanation
Correct answer: C
Primary concept: Standard V(B) requires communication about services and associated client costs, not just investment logic.
Decisive fact: Clients need the economic and service boundary to evaluate the relationship.
Explanation: C is correct because clients must understand what the automated platform will and will not do and the adviser and third-party costs they will bear before deciding whether the service fits their needs. A is wrong because historical return alone omits the service scope, constraints, risks, and fees. B is wrong because a programming language is not a substitute for decision-useful communication about the basic process, material limitations, and economic terms.
Question 70 · Module 6
An analyst states, "The company signed a five-year supply contract, and I estimate that earnings will grow 12%." To comply with Standard V(B), the analyst should most importantly:
- Adistinguish the signed contract as fact from the earnings forecast as an estimate.
- Blabel both statements as guaranteed facts.
- Comit the contract because facts may not appear beside opinions.
Check answer and explanation
Correct answer: A
Primary concept: Distinguish factual information from opinion or estimate.
Decisive fact: One statement is an observed event; the other is a forecast.
Explanation: A is correct because the signed contract is an observed fact while the 12% earnings growth figure is the analyst's forecast; clearly distinguishing them lets recipients assess certainty and assumptions. B is wrong because labeling an estimate as a guaranteed fact misrepresents unavoidable forecasting uncertainty. C is wrong because Standard V(B) permits facts and opinions in the same communication when their different status is made clear rather than blurred.
Question 71 · Module 6
A firm materially changes its valuation model from a dividend-discount approach to a machine-learning forecast but tells clients only that "our process has been refreshed." The firm most likely:
- Acomplies because model changes are always confidential.
- Bcomplies if the new output is more accurate.
- Cviolates Standard V(B) by failing to communicate a material change and its relevant limitations.
Check answer and explanation
Correct answer: C
Primary concept: Communicate the basic process, material changes, significant risks, and limitations.
Decisive fact: The analytical foundation changes materially while the communication hides the substance.
Explanation: C is correct because replacing the core valuation method is a material process change, and clients need its relevant assumptions, risks, and limitations to interpret recommendations. A is wrong because model changes are not categorically confidential. B is wrong because improved realised accuracy would not cure the failure to communicate information that was material when clients evaluated the process.
Question 72 · Module 6
A platform adds a material third-party custody fee after clients enroll. Under Standard V(B), the firm should most appropriately:
- Ainform affected clients clearly and promptly about the cost change.
- Bdisclose it only to new clients.
- Comit it because the fee is paid to a third party rather than the adviser.
Check answer and explanation
Correct answer: A
Primary concept: Client communication includes relevant costs from the adviser and associated third parties.
Decisive fact: The service economics change materially for existing clients.
Explanation: A is correct because the new custody fee materially changes what existing clients pay for the service, so clear and prompt notice is necessary for them to evaluate the relationship. B is wrong because limiting disclosure to new clients withholds a material cost change from the people already bearing it. C is wrong because Standard V(B)'s cost communication is not limited to fees retained by the adviser; a material third-party fee paid by clients remains decision-useful.
Question 73 · Module 6
An employee creates research records as part of her work. On departure, she wants to take all originals to prove her investment process. Unless law or an agreement provides otherwise, the records most likely:
- Abelong to the employee because she performed the analysis.
- Bbelong to the firm, so she should not remove them without permission.
- Cmay be destroyed immediately if the recommendation has expired.
Check answer and explanation
Correct answer: B
Primary concept: Professional records created for an employer are generally firm property.
Decisive fact: The analyst created the records within her employment and seeks to remove the firm's originals.
Explanation: B is correct because research records created within employment are generally the firm's property, so the departing employee may not remove the originals merely because she performed the analysis. A is wrong because the employee's authorship effort does not override employer ownership or authorization requirements. C is wrong because an expired recommendation does not make its supporting record disposable; applicable law, firm policy, and the need to reconstruct the basis still govern retention.
Question 74 · Module 6
A firm maintains complete, secure, indexed electronic records of analysis and approvals, with reliable access and retention controls. Under Standard V(C), electronic format:
- Acan satisfy the Standard; paper is not universally required.
- Bviolates the Standard because only original paper is acceptable.
- Cis acceptable only if no models are used.
Check answer and explanation
Correct answer: A
Primary concept: Record adequacy depends on content, security, accessibility, and applicable policy, not paper form alone.
Decisive fact: The electronic system preserves complete and retrievable evidence.
Explanation: A is correct because Standard V(C) focuses on preserving complete, secure, accessible evidence supporting professional work; the described electronic system can satisfy those functions without paper originals. B is wrong because the Standard does not impose a universal paper-only format. C is wrong because using models affects which inputs, assumptions, approvals, and outputs should be retained, but it does not make a properly controlled electronic record system unacceptable.
Question 75 · Module 6
No law or firm policy specifies a retention period for investment records. CFA Institute guidance recommends that the member retain records for at least:
- Aone year.
- Bseven years.
- Cthe life of the member.
Check answer and explanation
Correct answer: B
Primary concept: Seven years is the recommended minimum when no controlling period exists.
Decisive fact: Law and employer policy are silent.
Explanation: B is correct because, when law and firm policy are silent, CFA Institute guidance recommends at least seven years as a prudent retention period. A is wrong because one year is shorter than the recommended period and may not preserve an adequate history. C is wrong because lifetime retention is not the stated guidance; applicable law or a reasonable firm policy may set a different period.
Question 76 · Module 6
An analyst copies the firm's complete research archive to a personal cloud account before resigning, explaining that no files were deleted and the copies may help defend past recommendations. The analyst most likely:
- Acomplies because record preservation always permits personal copying.
- Bcomplies if the cloud provider uses encryption.
- Cviolates duties because firm-owned records and confidential material may not be removed without authorization.
Check answer and explanation
Correct answer: C
Primary concept: Preserve required records while respecting firm ownership, confidentiality, and authorized systems.
Decisive fact: The analyst removes a complete firm archive without permission.
Explanation: C is correct because copying the entire employer archive to a personal account without authorization removes firm-owned records and potentially confidential material from approved controls. A is wrong because a desire to preserve evidence does not create a personal ownership or copying exception; records should remain within authorized systems. B is wrong because encryption addresses only one security risk and does not cure the lack of permission, employer ownership, retention governance, or client confidentiality concerns.
Question 77 · Module 6
A committee relies on an external adviser whose work was originally approved. The adviser's strategy, personnel, and risk controls later change materially. Committee members should most appropriately:
- Acontinue automatically because initial approval is permanent.
- Breassess the adviser's work and continue to exercise independent judgment.
- Caccept the adviser’s conclusions without review because group decisions dilute individual responsibility.
Check answer and explanation
Correct answer: B
Primary concept: External advisers and group processes do not remove the member's diligence and judgment duties.
Decisive fact: Material changes undermine the basis for earlier reliance.
Explanation: B is correct because material changes to the adviser's strategy, personnel, and controls undermine the facts supporting the original approval and therefore require renewed due diligence and independent judgment. A is wrong because approval is not permanent when relevant circumstances change. C is wrong because using an external adviser or voting as part of a committee does not eliminate each member's responsibility to evaluate the work reasonably within that member's role.
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Module 7
Standard VI: Conflicts of Interest
Questions 78-87 · 10 questions
Question 78 · Module 7
Standard VI(A)'s preferred sequence begins with:
- Aavoiding a conflict when reasonably possible.
- Bhiding the conflict if disclosure might alarm a client.
- Caccepting the conflict first and disclosing it only after a complaint.
Check answer and explanation
Correct answer: A
Primary concept: Avoid or disclose conflicts; the revised rule expressly begins with reasonable avoidance.
Decisive fact: Disclosure is not the first response when the conflict can reasonably be prevented.
Explanation: A is correct because the preferred first step is to avoid a conflict when reasonably possible, before relying on disclosure and management. B is wrong because concealment prevents clients and employers from evaluating impaired judgment. C is wrong because accepting a conflict and waiting for a complaint is reactive, leaves recipients uninformed, and does not satisfy the duty to address conflicts proactively.
Question 79 · Module 7
An analyst inherits a large position in a company she covers. Reassigning coverage is practicable. What is the most appropriate response?
- AKeep the assignment and make a hidden promise to remain neutral.
- BSell immediately even if employer rules prohibit trading during the period.
- CReport the holding, pursue practical avoidance or mitigation such as reassignment, and make any required disclosure.
Check answer and explanation
Correct answer: C
Primary concept: Avoid, mitigate, and disclose conflicts in a way that lets affected parties evaluate them.
Decisive fact: The analyst has a material ownership conflict and a practical reassignment option.
Explanation: C is correct because the inherited holding is a material conflict and reassignment is a practical way to avoid it; prompt reporting, applicable restrictions, and any residual disclosure make the response effective. A is wrong because a private promise of neutrality neither removes nor communicates the conflict. B is wrong because an immediate sale could breach employer trading restrictions and is not the only lawful solution; conflict avoidance must be implemented through workable controls.
Question 80 · Module 7
A research report discloses the analyst's material ownership in the covered issuer in pale six-point text on the final page. The disclosure is technically present but difficult to notice. It most likely:
- Acomplies because any disclosure is sufficient.
- Bcomplies if the analyst's opinion is accurate.
- Cfails Standard VI(A) because disclosure must be prominent, plain, and effective for the audience.
Check answer and explanation
Correct answer: C
Primary concept: Conflict disclosure must be full and fair, prominent, understandable, and timely.
Decisive fact: The design makes a material conflict practically invisible.
Explanation: C is correct because a disclosure must be sufficiently prominent, understandable, and accessible to communicate the conflict effectively to the intended reader. A is wrong because mere technical presence in unreadable text is not full and fair disclosure. B is wrong because analytical accuracy does not remove the ownership incentive or help readers assess its possible influence.
Question 81 · Module 7
A manager has a pending client buy order. Before entering that order, she buys the same security for her personal account. She most likely:
- Aviolates Standard VI(B) because client and employer transactions must receive priority over beneficially owned personal transactions.
- Bcomplies if her personal order is small.
- Ccomplies because personal accounts always have equal priority.
Check answer and explanation
Correct answer: A
Primary concept: Transactions for clients and employers take priority over transactions in which the member is a beneficial owner.
Decisive fact: The manager trades personally ahead of a pending client order.
Explanation: A is correct because a manager who knows of a pending client order must not place a beneficial personal transaction ahead of it. B is wrong because even a small order can obtain price or timing advantages and there is no size-based safe harbor. C is wrong because Standard VI(B) expressly gives client and employer transactions priority rather than equal status with personal trades.
Question 82 · Module 7
A member can direct trades in a family trust but is not the named owner of its securities. For transaction-priority purposes, the member most likely:
- Ahas no relevant interest because legal title is elsewhere.
- Bhas no relevant interest unless the trust pays advisory fees.
- Cmay be a beneficial owner because control or economic exposure can matter beyond legal title.
Check answer and explanation
Correct answer: C
Primary concept: Beneficial ownership is broader than the name on an account.
Decisive fact: The member controls trading through the trust.
Explanation: C is correct because beneficial ownership is determined substantively: control over trading or economic exposure can make the trust relevant even when legal title appears in another name. A is wrong because relying only on the named owner would let controlled family or trust accounts evade transaction-priority rules. B is wrong because whether the trust pays advisory fees determines neither the member's control nor economic interest and therefore does not resolve beneficial ownership.
Question 83 · Module 7
A manager owns 12% of a private investment club and can direct its brokerage account. Before executing a large client order, she buys the same security for the club. The manager most likely:
- Acomplies because an investment club is not a personal account.
- Bviolates Standard VI(B) because her ownership and control create a beneficial interest traded ahead of the client.
- Ccomplies if the club has more than five members.
Check answer and explanation
Correct answer: B
Primary concept: Personal investing is controlled through beneficial ownership, not merely account labels.
Decisive fact: The manager has both economic exposure and transaction control.
Explanation: B is correct because the manager's ownership and control create a beneficial interest in the club account, so buying before the client can violate transaction priority. A is wrong because the name “investment club” does not determine beneficial ownership. C is wrong because the number of club members creates no automatic exception; the economic interest and ability to control the trade are decisive.
Question 84 · Module 7
A wealth adviser will receive 20% of the first year's fee for referring a client to a tax specialist. To comply with Standard VI(C), the adviser should most appropriately:
- Adisclose the nature and estimated value of the benefit before the client enters the service arrangement.
- Bdisclose only after the client has paid the tax specialist.
- Cmake no disclosure because the benefit is paid by the specialist.
Check answer and explanation
Correct answer: A
Primary concept: Disclose referral compensation received from or paid to others for recommending products or services.
Decisive fact: The client should know the economic incentive before relying on the recommendation.
Explanation: A is correct because the client must know the nature and estimated value of the adviser's 20% referral benefit before deciding whether to rely on the recommendation and enter the tax-service arrangement. B is wrong because disclosure after payment cannot inform the client's original decision. C is wrong because Standard VI(C) covers referral consideration the member receives from another party as well as consideration the member pays to obtain referrals.
Question 85 · Module 7
An estate lawyer gives an adviser a valuable software subscription for every referred client. No cash changes hands. The benefit most likely:
- Afalls outside Standard VI(C) because only cash counts.
- Bis referral consideration whose nature and estimated value should be disclosed.
- Crequires disclosure only if the software improves performance.
Check answer and explanation
Correct answer: B
Primary concept: Referral benefits include noncash consideration.
Decisive fact: The subscription is valuable and contingent on referrals.
Explanation: B is correct because a valuable software subscription earned for each referral is noncash consideration whose nature and estimated value can influence the adviser's recommendation and therefore must be disclosed. A is wrong because Standard VI(C) is not limited to cash payments; valuable services and benefits also count. C is wrong because disclosure turns on the economic incentive attached to the referral, not whether the software later improves investment performance.
Question 86 · Module 7
An outside service pays a recurring referral fee directly to an employee, and the fee could influence both client recommendations and the employee's duties to the employer. Which statement is most accurate?
- AOnly Standard VI(C) can apply to a referral benefit.
- BOnly Standard IV(B) can apply because the employee receives it personally.
- CThe same benefit can trigger referral disclosure under VI(C) and employer consent duties under IV(B).
Check answer and explanation
Correct answer: C
Primary concept: One economic benefit can activate more than one conflict or consent mechanism.
Decisive fact: The payment influences client-facing referrals and creates outside compensation conflicting with employment.
Explanation: C is correct because one payment can be both referral consideration requiring client disclosure and outside compensation requiring prior written employer consent. A is wrong because Standard VI(C) does not displace duties to the employer. B is wrong because Standard IV(B) does not eliminate the need to tell clients or prospects about an incentive that may influence the recommendation.
Question 87 · Module 7
An analyst owns a material stake in an issuer she covers. Reassignment is not practical because she is the firm's only sector specialist. She should most appropriately:
- Adisclose the interest to the employer and affected clients, follow restrictions, and use mitigation such as independent review.
- Bsay nothing because expertise makes the conflict harmless.
- Cpublish first and disclose only if the recommendation moves the price.
Check answer and explanation
Correct answer: A
Primary concept: When reasonable avoidance is not practical, mitigate and disclose the remaining conflict effectively.
Decisive fact: The ownership could impair or appear to impair objectivity, while reassignment is unavailable.
Explanation: A is correct because when avoidance through reassignment is impractical, full disclosure, trading restrictions, and independent review can help recipients and the firm manage the conflict. B is wrong because expertise does not neutralize a material ownership interest. C is wrong because disclosure must inform judgment before publication or action; it cannot depend on whether the price later moves.
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Module 8
Standard VII: Responsibilities as a CFA Institute Member or CFA Candidate
Questions 88-95 · 8 questions
Question 88 · Module 8
After an exam, a candidate posts, "The afternoon session tested a particular unannounced topic twice." No exact question is quoted. The candidate most likely:
- Aviolates Standard VII(A) because topic-level information about what was tested remains confidential.
- Bcomplies because only exact wording is protected.
- Ccomplies because the exam has ended.
Check answer and explanation
Correct answer: A
Primary concept: Exam confidentiality includes tested topics, formulas, emphasis, and other content—not only exact questions.
Decisive fact: The post reveals what appeared and how often.
Explanation: A is correct because disclosing that a particular unannounced topic appeared twice reveals protected examination content and emphasis even without reproducing an exact question. B is wrong because Standard VII(A) protects more than verbatim wording, including tested topics and relative emphasis. C is wrong because completion of the session does not end the candidate's confidentiality obligation or eliminate the unfair advantage the disclosure could give future examinees.
Question 89 · Module 8
Which statement may a candidate generally make without violating exam confidentiality?
- A"A specific case on the exam used a pension sponsor."
- B"The public curriculum includes pension-fund duties."
- C"The second session did not test market manipulation."
Check answer and explanation
Correct answer: B
Primary concept: Public curriculum content may be discussed; confidential tested or untested exam content may not.
Decisive fact: B refers only to information already publicly released in the curriculum.
Explanation: B is correct because it refers only to publicly available curriculum coverage and reveals nothing about a particular examination. A is wrong because identifying a specific tested case discloses confidential exam content even without exact wording. C is wrong because telling others what was absent also reveals the composition and emphasis of the examination.
Question 90 · Module 8
A candidate sends one friend a private disappearing message describing an exam formula and asks the friend not to share it. The candidate most likely:
- Acomplies because the message is private.
- Bcomplies because disappearing messages leave no evidence.
- Cviolates Standard VII(A) because confidentiality does not depend on audience size, platform, or message persistence.
Check answer and explanation
Correct answer: C
Primary concept: Private transmission can compromise exam integrity just like public posting.
Decisive fact: Confidential exam content is deliberately shared with an unauthorized person.
Explanation: C is correct because exam confidentiality applies regardless of whether the audience is one person or many and whether the message remains stored. A is wrong because a private channel does not authorize disclosure of protected content. B is wrong because disappearing technology changes the evidence trail, not the candidate's duty or the potential unfair advantage given to the recipient.
Question 91 · Module 8
A person registered for the February 2027 Level I exam withdraws and is not registered for another exam or awaiting results. In August 2027, the person states, "I am a CFA candidate." The statement most likely:
- Ais accurate because candidacy lasts forever after first registration.
- Bis inaccurate because candidacy is a temporary current status.
- Cis accurate if the person plans to register again someday.
Check answer and explanation
Correct answer: B
Primary concept: CFA Program candidacy depends on current enrollment, active participation, or awaiting results under the applicable status rules.
Decisive fact: The person has withdrawn and has no current registration or pending result.
Explanation: B is correct because candidacy describes a current, defined relationship—such as registration for an examination or awaiting results—not a permanent status after any past registration. A is wrong because candidacy does not last for life. C is wrong because a future intention to register does not make the person a candidate today and cannot support the present-tense claim.
Question 92 · Module 8
An individual passed Level I but is not currently a candidate. Which description is most appropriate?
- A"Passed Level I of the CFA Program."
- B"CFA, Level I."
- C"CFA charter pending."
Check answer and explanation
Correct answer: A
Primary concept: State factual exam progress without creating a partial designation or implying future status.
Decisive fact: Passing a level is a result, not a credential after the name.
Explanation: A is correct because it states the individual's actual historical achievement—passing Level I—without suggesting a credential, current candidacy, or guaranteed progression. B is wrong because “CFA, Level I” creates a nonexistent partial designation and improperly uses CFA as a suffix. C is wrong because “charter pending” implies that award of the charter is assured and may also imply a current status the facts expressly deny.
Question 93 · Module 8
A former charterholder has not renewed membership or submitted the required annual statement but continues using "CFA" after her name. She most likely:
- Acomplies because earning the charter creates permanent usage rights.
- Bviolates Standard VII(B) because use of the designation depends on current good standing.
- Ccomplies if she used the designation accurately in the past.
Check answer and explanation
Correct answer: B
Primary concept: The right to use the CFA designation depends on satisfying continuing membership requirements.
Decisive fact: The former charterholder is not currently in good standing.
Explanation: B is correct because use of the CFA designation requires the charterholder to maintain the applicable membership status and complete required annual obligations; the former charterholder has not done so. A is wrong because earning the charter does not create an unconditional lifetime right to use the letters. C is wrong because accurate use in an earlier period of good standing does not authorize a present-tense designation after the continuing requirements lapse.
Question 94 · Module 8
A charterholder advertises, "Because I hold the CFA charter, my clients can expect superior returns." The statement most likely:
- Aviolates Standard VII(B) because the designation does not promise superior performance or CFA Institute endorsement.
- Bcomplies if the charterholder outperformed last year.
- Ccomplies because charterholders may make any claim about the designation.
Check answer and explanation
Correct answer: A
Primary concept: References to CFA Institute, membership, candidacy, or the designation must be factual and not exaggerated.
Decisive fact: The advertisement turns a credential into a performance guarantee.
Explanation: A is correct because linking possession of the CFA charter to expected superior returns exaggerates the designation and implies a performance assurance or endorsement that it does not provide. B is wrong because one year's outperformance cannot make that general implication accurate or permissible. C is wrong because charterholders may reference the designation only factually and must not overstate what CFA Institute membership or the credential signifies.
Question 95 · Module 8
Professional Conduct requests relevant records from a member in an authorized inquiry. The member deletes the records because he considers the complaint unfair. The member most likely:
- Acomplies because respondents decide which evidence is relevant.
- Bcomplies if the underlying complaint is eventually dismissed.
- Cviolates Standard VII(A) by obstructing an authorized professional conduct process.
Check answer and explanation
Correct answer: C
Primary concept: Covered persons must cooperate with professional conduct inquiries and preserve requested evidence.
Decisive fact: The member intentionally destroys information sought in the inquiry.
Explanation: C is correct because intentionally deleting requested records obstructs an authorized CFA Institute professional conduct inquiry and breaches the member's cooperation duty under Standard VII(A). A is wrong because the respondent cannot unilaterally decide that requested evidence is irrelevant and destroy it. B is wrong because a later dismissal of the underlying complaint would not retroactively excuse destruction that impaired the integrity of the investigative process.
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Module 9
Integrated Application
Questions 96-101 · 6 questions
Question 96 · Module 9
Lina markets a token only in Country M. Country M law governs the offering and requires a risk disclosure absent from the website. Lina's manager tells her that another country's law is less strict and orders the launch. Lina should most appropriately:
- Aapply Country M's governing requirement, seek to stop the launch, and dissociate if the violation continues.
- Buse the less strict foreign law because the firm operates internationally.
- Claunch first and add the disclosure after any investor complaint.
Check answer and explanation
Correct answer: A
Primary concept: Standard I(A), Knowledge of the Law, and the dissociation duty.
Decisive fact: Country M law is expressly applicable to the offering.
Explanation: A is correct because Country M's law expressly governs this offering, so Lina must include its required risk disclosure, seek to stop the noncompliant launch, and dissociate if the violation continues. B is wrong because a less strict foreign rule does not displace the law applicable to the actual offering. C is wrong because knowingly launching first participates in the violation; a later complaint or correction cannot authorize omission of a disclosure required at launch.
Question 97 · Module 9
An analyst hosts a livestream about an issuer while receiving an undisclosed issuer payment. The analysis is well supported and factually accurate. Which statement is most accurate?
- AAccuracy eliminates every other ethical concern.
- BOnly record retention can be violated because the analysis has a reasonable basis.
- CThe payment can impair independence and requires prominent conflict disclosure even when the analysis is accurate.
Check answer and explanation
Correct answer: C
Primary concept: Standard I(B), Independence and Objectivity, and Standard VI(A), Conflicts of Interest.
Decisive fact: The audience cannot evaluate a material financial incentive that remains hidden.
Explanation: C is correct because the undisclosed issuer payment creates a financial incentive that can impair or appear to impair independence, so prominent conflict disclosure and appropriate safeguards remain necessary even when the analysis is accurate. A is wrong because truthful output does not erase a conflicted process or the audience's need to assess the incentive. B is wrong because the central duties are independence and conflict disclosure, not merely retention of records.
Question 98 · Module 9
During an expert call, an analyst hears a specific unannounced production failure likely to affect an issuer's value. The analyst immediately posts a vague but actionable rumor that prompts followers to sell, although the analyst does not trade. The analyst most likely:
- Acomplies because only personal trading is prohibited.
- Bviolates only Standard II(B), because online posts are always manipulation.
- Cmay violate Standard II(A) by causing others to act on material nonpublic information, regardless of personal trading.
Check answer and explanation
Correct answer: C
Primary concept: Standard II(A) prohibits acting or causing others to act on material nonpublic information.
Decisive fact: The post transmits an actionable signal derived from specific, price-sensitive, unannounced information.
Explanation: C is correct because the analyst turns specific material nonpublic information into an actionable signal that prompts followers to sell, thereby causing others to act even though the analyst does not trade personally. A is wrong because Standard II(A) expressly reaches causing others to act. B is wrong because an online post is not automatically manipulation; Standard II(B) would require additional facts showing deceptive or price-distorting intent, whereas the information violation is directly established.
Question 99 · Module 9
A pension manager directs brokerage to a dealer that helped the sponsor's executives personally and pays the manager an undisclosed referral benefit. The beneficiaries receive no advantage. Which combination most directly captures the violations?
- AStandard I(E) only, because the manager lacks technical competence.
- BStandard III(A) for failing to serve the pension client and Standard VI(C) for the referral benefit; conflict disclosure duties may also apply.
- CStandard VII(B) only, because the CFA designation is involved.
Check answer and explanation
Correct answer: B
Primary concept: Loyalty to the actual client and disclosure of referral incentives.
Decisive fact: Client brokerage is diverted for personal and sponsor-executive benefit, and the manager receives an undisclosed referral benefit.
Explanation: B is correct because the manager diverts client brokerage away from beneficiary interests and receives referral consideration that must be disclosed; the facts may also activate broader conflict duties. A is wrong because the scenario shows disloyal incentives rather than missing technical knowledge or skills. C is wrong because no claim about CFA status or the designation is involved.
Question 100 · Module 9
A supervisor deploys an untested artificial-intelligence portfolio engine. Staff report unstable allocations, but she tells them to continue, suppresses warnings, and describes the process to clients as "fully validated." Which duties are most directly implicated?
- AOnly Standard VI(B), Transaction Priority.
- BStandard I(E) competence, Standard IV(C) supervision, Standard V(A) reasonable basis, and Standard I(C) truthful communication.
- CNo duties until a client loses money.
Check answer and explanation
Correct answer: B
Primary concept: Competence, supervision, reasonable basis, and non-misleading communication operate together.
Decisive fact: The supervisor knows the tool is unstable, fails to investigate, and makes a false validation claim.
Explanation: B is correct because the supervisor deploys a system she has not competently evaluated, ignores red flags she must supervise, lacks a reasonable basis for continued use, and falsely calls the system validated. A is wrong because no client-versus-personal trade priority issue is presented. C is wrong because all four duties are process-based and can be violated before a client suffers a measurable loss; waiting for harm would not cure the known deficiencies.
Question 101 · Module 9
A manager advertises a "perfect ten-year record" after removing closed accounts, retaining no supporting calculation files, and omitting material fees. Which combination is most directly implicated?
- AStandard III(D) for misleading performance and Standard V(C) for inadequate supporting records; Standard I(C) may also apply.
- BStandard II(A) only, because performance data is nonpublic information.
- CStandard VII(A) only, because the advertisement affects CFA Program integrity.
Check answer and explanation
Correct answer: A
Primary concept: Fair performance presentation, record retention, and truthful communication.
Decisive fact: The claim is selectively constructed, economically incomplete, and unsupported by retained evidence.
Explanation: A is correct because removing closed accounts and omitting fees makes the performance claim misleading under Standard III(D), while the missing calculation files breach the need to retain support under Standard V(C); the false overall impression may also violate I(C). B is wrong because the facts concern selective advertising, not trading on material nonpublic information. C is wrong because no exam, professional conduct inquiry, or misuse of CFA status invokes Standard VII(A).
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Module 10
Advanced Mixed Cases
Questions 102-163 · 62 questions
Question 102 · Module 10
Nadia works in Country R, where local law permits selective disclosure of a recommendation to favored institutions. Her employer's global policy and the Code and Standards require fair dissemination. She is told to follow the local custom. Nadia should most appropriately:
- Afollow local custom because any legally permitted practice satisfies Standard I(A).
- Bfollow the stricter professional requirement and seek to distribute the recommendation fairly.
- Cresign immediately without first attempting to prevent or dissociate from the conduct.
Check answer and explanation
Correct answer: B
Primary concept: Standard I(A) requires the stricter applicable law, regulation, or professional standard when requirements differ.
Decisive fact: Local law permits the practice, but a stricter professional requirement still governs Nadia's conduct.
Explanation: B is correct because legal permission is only the floor when the Code and Standards impose a higher duty. A is wrong because Standard I(A) does not treat the least strict legal rule as sufficient. C is wrong because Nadia should first try to stop the conduct and dissociate if it continues; immediate resignation is not automatically required.
Question 103 · Module 10
After years managing government bonds, Oliver accepts responsibility for a complex options-overlay mandate. He has read a short product brochure but cannot explain the strategy's nonlinear risks. Before trading, he should most appropriately:
- Aproceed because competence in one asset class transfers automatically to all portfolio roles.
- Bproceed if the client signs a broad risk acknowledgment.
- Cobtain the necessary knowledge or qualified support before undertaking the new responsibility.
Check answer and explanation
Correct answer: C
Primary concept: Standard I(E) requires members and candidates to act with and maintain the competence needed for their specific professional responsibilities.
Decisive fact: Oliver's prior expertise does not give him the knowledge and skills needed to manage the proposed options strategy safely.
Explanation: C is correct because competence is role-specific and must exist before Oliver performs the unfamiliar work. A is wrong because expertise in government bonds does not automatically establish derivatives competence. B is wrong because a client's acknowledgment of risk cannot waive the professional's own duty to possess the knowledge, skills, and abilities required for the mandate.
Question 104 · Module 10
An issuer offers Mei, an equity analyst, business-class travel and a week at a luxury resort to attend a two-hour plant tour. Her employer could pay reasonable travel costs. Which response is most appropriate?
- ADecline the lavish package and arrange ordinary travel that preserves her independence.
- BAccept because the plant tour may improve the factual basis of her report.
- CAccept if she promises the issuer that her recommendation will remain unchanged.
Check answer and explanation
Correct answer: A
Primary concept: Standard I(B) requires members and candidates to protect independence and objectivity from gifts or benefits that could compromise judgment.
Decisive fact: The issuer's package is lavish and substantially exceeds what is necessary to conduct the research visit.
Explanation: A is correct because reasonable arrangements may be acceptable, but an extravagant issuer-paid benefit creates a serious threat to perceived and actual objectivity. B is wrong because potential research value does not justify unnecessary luxury. C is wrong because a private promise does not remove the influence, appearance problem, or disclosure and approval concerns created by the benefit.
Question 105 · Module 10
A research director presents a machine-learning forecast as “analyst-verified” even though no analyst reviewed the input data or the model's output. The forecast happens to be accurate. The director most likely:
- Acomplies because an accurate outcome cures any weakness in the process description.
- Bviolates the prohibition on misrepresentation by making a false statement about verification.
- Cviolates only if a client trades and subsequently incurs a loss.
Check answer and explanation
Correct answer: B
Primary concept: Standard I(C) prohibits knowingly making false or misleading statements about an investment process or service.
Decisive fact: The director represents that human verification occurred when no such review took place.
Explanation: B is correct because the process claim is false regardless of whether the forecast later proves accurate. A is wrong because a fortunate outcome does not make the earlier representation truthful. C is wrong because misconduct under Standard I(C) does not depend on a completed trade or measurable client loss; the misleading communication itself creates the violation.
Question 106 · Module 10
While serving as volunteer treasurer of a community investment fund—a role she was asked to take because of her investment credentials—a portfolio manager repeatedly falsifies expense receipts. The conduct never appears in client accounts. Under Standard I(D), the manager's conduct most likely:
- Ais outside the Standards because it did not occur at the investment firm.
- Bmay violate the Standard because repeated dishonesty reflects adversely on professional integrity.
- Cviolates only if the community organization is also an investment client.
Check answer and explanation
Correct answer: B
Primary concept: Standard I(D) covers professional misconduct involving dishonesty, fraud, deceit, or conduct reflecting adversely on professional reputation, integrity, or competence.
Decisive fact: The receipt fraud occurs in a role obtained through and relying on the manager's professional investment status.
Explanation: B is correct because intentional receipt fraud in a role undertaken because of the manager's investment credentials is professional conduct involving dishonesty and reflects adversely on integrity. A is wrong because professional conduct is not confined to paid employment or client accounts. C is wrong because the victim need not be an investment client; the professional nexus and the dishonest conduct are controlling.
Question 107 · Module 10
Priya combines public shipping data, a nonmaterial comment from a supplier, and her own industry model to conclude that an issuer will miss its earnings target. None of the pieces is material on its own. She may most appropriately:
- Aavoid using the conclusion because any nonpublic input makes the analysis prohibited.
- Btrade only after asking the supplier to publish the comment.
- Cact on the conclusion if it was reached through legitimate mosaic analysis and no input was material nonpublic information.
Check answer and explanation
Correct answer: C
Primary concept: Standard II(A) permits conclusions developed through the mosaic theory when they combine public information with nonmaterial nonpublic information.
Decisive fact: No individual nonpublic input is material, and Priya independently derives the investment conclusion.
Explanation: C is correct because the mosaic theory allows diligent analysis of public and nonmaterial nonpublic pieces. A is wrong because Standard II(A) does not prohibit every use of nonpublic information; materiality is critical. B is wrong because publication of the supplier's nonmaterial comment is not required, although Priya should document the research basis and avoid information she knows is material and nonpublic.
Question 108 · Module 10
A trader enters matched buy and sell orders between two controlled accounts solely to create the appearance of heavy market activity before selling to outside investors. The trader most likely violates:
- AStandard II(B), because the transactions intentionally create a false impression of trading activity.
- BStandard VI(B), because every trade between related accounts is automatically a personal transaction.
- Cno Standard if the matched orders execute at prevailing market prices.
Check answer and explanation
Correct answer: A
Primary concept: Standard II(B) prohibits transaction-based practices intended to mislead market participants or distort prices or trading volume.
Decisive fact: The orders have no investment purpose and are designed to manufacture an appearance of liquidity.
Explanation: A is correct because manipulative intent and the artificial volume are present even if each execution occurs at the current price. B is wrong because Standard VI(B) concerns priority between client and beneficial personal transactions, not every related-account trade. C is wrong because a market-price execution does not legitimize a scheme whose purpose is to mislead other investors about demand or liquidity.
Question 109 · Module 10
A portfolio manager says her decision to accept a client's off-mandate request must have been ethical, because the position later doubled in value and because she has always regarded herself as an honest professional. Which challenges to ethical behaviour does that reasoning show?
- ASituational pressure from the client, which excuses the decision because the client initiated it.
- BOutcome bias and overconfidence in her own ethics: a profit is being read as proof of a sound process, and self-image as proof of a sound choice.
- CA correct use of the ethical decision-making framework, because reflecting on results is its final step.
Check answer and explanation
Correct answer: B
Primary concept: Challenges to ethical behaviour include overconfidence in one's own ethics and judging a decision by its outcome rather than by the process and duties at the time.
Decisive fact: Neither the profitable outcome nor the manager's self-image tests whether the mandate and the client's interests were respected when the decision was made.
Explanation: B is correct because the manager is using two of the recognised shortcuts at once: outcome bias, which treats a good result as evidence of a good decision, and moral overconfidence, which treats being a good person as proof that a particular choice was ethical. A is wrong because a client's request is a situational influence to be recognised and managed, not an excuse that ends the analysis. C is wrong because the framework's reflection step reviews the process and its consequences; it does not license reading a profit backwards as proof that the earlier judgement was ethical.
Question 110 · Module 10
Before releasing a changed recommendation, a firm gives every client simultaneous notice. Premium clients receive a detailed webinar later that day under a previously disclosed service tier that is available to any client who elects it. The arrangement most likely:
- Aviolates fair dealing because every client must receive identical services at identical times.
- Bcomplies only if premium clients are prohibited from trading after the webinar.
- Cmay comply because fair dealing requires fairness, not identical service, when tiers are disclosed and the recommendation itself is disseminated fairly.
Check answer and explanation
Correct answer: C
Primary concept: Standard III(B) requires fair dealing in disseminating recommendations and taking investment action but does not require identical service to every client.
Decisive fact: All clients receive the changed recommendation simultaneously, and the later enhanced service was disclosed in advance and offered on an open, nonselective basis.
Explanation: C is correct because differentiated service may be fair when the service levels are disclosed, available to all clients on the same terms, and the core recommendation is disseminated fairly. A is wrong because fairness is not the same as absolute equality of service. B is wrong because a blanket trading prohibition is not required; the firm instead needs policies that provide fair dissemination and execution opportunity.
Question 111 · Module 10
A retired client asks an adviser to place half of a conservative income portfolio in a highly leveraged commodity fund after seeing an online advertisement. The adviser has discretionary authority. What should the adviser do first?
- Aexecute because the client's latest request automatically replaces the written investment policy statement.
- Breassess the client's circumstances and the mandate, discuss suitability, and update the investment policy before acting if appropriate.
- Crefuse permanently because leveraged products can never be suitable for an individual investor.
Check answer and explanation
Correct answer: B
Primary concept: Standard III(C) requires an adviser to understand the client's objectives and constraints and judge investments in the context of the total portfolio.
Decisive fact: The proposed concentration is inconsistent with the client's existing conservative income mandate and may reflect changed circumstances or misunderstanding.
Explanation: B is correct because the adviser must investigate the request, update client information and the investment policy when necessary, and assess the position in portfolio context. A is wrong because an impulsive request does not erase the agreed mandate. C is wrong because suitability is client- and portfolio-specific; leverage is not categorically prohibited for every individual.
Question 112 · Module 10
A manager presents the five-year return of the firm's surviving growth accounts and labels it “our growth strategy record,” while omitting three terminated accounts that performed poorly. Which action best corrects the presentation?
- AInclude all relevant discretionary accounts for the period and disclose the basis and material limitations of the result.
- BRetain the survivor-only figure but add the word “selected” in small print.
- CRemove the benchmark while leaving the account selection unchanged.
Check answer and explanation
Correct answer: A
Primary concept: Standard III(D) requires performance information to be fair, accurate, and complete and prohibits selective presentation that misleads prospects.
Decisive fact: Excluding terminated poor performers creates survivor bias and overstates the strategy's historical result.
Explanation: A is correct because a representative result requires the relevant accounts and sufficient disclosure for a fair evaluation. B is wrong because a vague label in small print does not cure materially biased selection. C is wrong because benchmark choice is not the central defect; removing it leaves the misleading survivor-only performance history intact.
Question 113 · Module 10
A former client tells an adviser privately that she concealed taxable income. The adviser is later served with a legally valid order requiring production of relevant client records. The adviser should most appropriately:
- Arefuse because confidentiality continues forever without exception.
- Bpublish the information broadly because suspected illegal activity removes every confidentiality duty.
- Cobtain appropriate legal guidance and disclose only as required or otherwise permitted under the confidentiality exceptions.
Check answer and explanation
Correct answer: C
Primary concept: Standard III(E) preserves current, former, and prospective client confidentiality except for illegal activity, legally required disclosure, or client permission.
Decisive fact: A valid legal order activates an exception, but it does not justify disclosure beyond the lawful purpose and scope.
Explanation: C is correct because the adviser should follow applicable law, seek counsel where appropriate, and limit disclosure to what the process requires. A is wrong because confidentiality is not absolute when law compels disclosure. B is wrong because an exception does not authorize indiscriminate publication; information should still be protected from unnecessary use or dissemination.
Question 114 · Module 10
Before leaving her employer, an analyst downloads the firm's confidential client list and proprietary model to launch a competing business. She has not yet contacted any clients. Her conduct most likely:
- Acomplies because solicitation has not begun.
- Bviolates her duty of loyalty by taking confidential employer property for personal competition.
- Ccomplies if she helped develop part of the model while employed.
Check answer and explanation
Correct answer: B
Primary concept: Standard IV(A) prohibits members and candidates from harming an employer through misuse of confidential information, records, or other employer property.
Decisive fact: The analyst removes confidential client data and a proprietary model before ending the employment relationship.
Explanation: B is correct because the unauthorized taking itself breaches loyalty even before the analyst solicits a client. A is wrong because the duty is not limited to completed solicitation. C is wrong because work created within employment may belong to the employer; contributing to it does not authorize taking confidential files, although the analyst may use general experience and skills after departure.
Question 115 · Module 10
A research analyst is asked by a privately held company to provide evening strategic advice in exchange for share warrants. The company operates in the sector the analyst covers, and the analyst's employer does not know of the proposal. Before accepting, the analyst must most appropriately:
- Await until the warrants vest and then tell the employer as part of the annual compliance certification.
- Bdisclose the terms to the company and employer and obtain written consent from all parties involved before beginning the advisory work.
- Caccept without consent because the benefit is non-cash and the advice would be given outside normal working hours.
Check answer and explanation
Correct answer: B
Primary concept: Standard IV(B) requires written consent from all parties before accepting compensation or benefits that may create a conflict with employer interests.
Decisive fact: Equity-linked payment for overlapping professional services can affect the analyst's independence and conflict with the existing employment relationship.
Explanation: B is correct because full disclosure and prior written consent let both the paying company and the employer evaluate the outside work, equity incentive, and overlap with the analyst's assigned coverage. A is incorrect because disclosure after vesting occurs too late; the conflict exists before the analyst accepts or performs the work. C is incorrect because compensation can conflict with employer interests whether it is paid in cash or warrants and whether the services occur during or outside office hours.
Question 116 · Module 10
A compliance officer gives a supervisor credible evidence that a trader has overridden pre-trade controls. The supervisor does not investigate because the trader is highly profitable. What is the supervisor's most appropriate response?
- AInvestigate promptly, stop or limit the activity as needed, and strengthen the procedures that failed.
- BWait for a regulator to prove a violation before taking any internal action.
- CDelegate the matter back to the trader because profitable employees may self-supervise.
Check answer and explanation
Correct answer: A
Primary concept: Standard IV(C) requires reasonable efforts to prevent and detect violations by persons subject to a member's supervision.
Decisive fact: The supervisor has credible notice of a control override and chooses profit over investigation and prevention.
Explanation: A is correct because a supervisor must respond reasonably to warning signs, investigate, restrict activity if necessary, and address deficient controls. B is wrong because supervisory responsibility is proactive and does not begin only after regulatory proof. C is wrong because delegating oversight to the suspected trader is not a reasonable prevention or detection procedure.
Question 117 · Module 10
An analyst recommends a thinly traded bond after relying only on an anonymous social-media post. Two reputable data sources and the issuer's filings are readily available but are not reviewed. The analyst most likely:
- Acomplies because timely recommendations may rely on any single source.
- Bviolates only if the anonymous post later proves false.
- Cviolates the reasonable-basis duty by failing to conduct diligent, independent research before recommending the bond.
Check answer and explanation
Correct answer: C
Primary concept: Standard V(A) requires diligence, independence, thoroughness, and a reasonable and adequate basis supported by appropriate research.
Decisive fact: The analyst ignores accessible, credible evidence and bases a recommendation solely on an unverified anonymous claim.
Explanation: C is correct because the process lacks the investigation needed for a reasonable basis, particularly for an illiquid security. A is wrong because speed does not excuse inadequate research or source evaluation. B is wrong because the duty focuses on the quality of the process at the time of the recommendation, not solely on whether the unsupported claim later happens to be true.
Question 118 · Module 10
A quantitative manager changes a model's volatility assumption, materially increasing the strategy's back-tested return. In a client presentation, she describes the model but omits the changed assumption and its sensitivity. She most likely:
- Acomplies because clients need only the final return estimate.
- Bviolates the communication duty by omitting a material limitation and a significant change in the investment process.
- Cviolates only the record-retention duty, provided the model file is saved.
Check answer and explanation
Correct answer: B
Primary concept: Standard V(B) requires disclosure of the basic investment process, significant limitations and risks, and material changes affecting a recommendation or strategy.
Decisive fact: The undisclosed assumption change materially drives the attractive back-test and affects how clients should interpret the result.
Explanation: B is correct because clients need enough information to understand the process and the sensitivity of the claim. A is wrong because a final estimate without a material assumption can mislead. C is wrong because retaining the file may satisfy part of Standard V(C), but it does not cure the separate failure to communicate the significant model change and limitation.
Question 119 · Module 10
An analyst leaves a firm and deletes all supporting work for reports she wrote there because she considers the spreadsheets her personal intellectual property. The firm's policy requires retaining research records for seven years. Which statement is most accurate?
- AThe records generally belong to the firm, and destroying them conflicts with Standard V(C) and the employer's retention policy.
- BThe analyst may delete them because authors always own every work product they create while employed.
- CThe analyst must keep personal copies even if doing so would violate employer confidentiality rules.
Check answer and explanation
Correct answer: A
Primary concept: Standard V(C) requires appropriate records supporting investment analysis, recommendations, actions, and related communications to be maintained.
Decisive fact: The analyst intentionally destroys employer records that support published research and remain within the required retention period.
Explanation: A is correct because records created for the employer are generally firm property and must be preserved according to law and policy. B is wrong because authorship does not grant unilateral destruction rights over employer work product. C is wrong because the analyst need not—and often should not—take confidential copies; responsibility for retention after departure ordinarily remains with the firm.
Question 120 · Module 10
A director owns shares in a supplier that will benefit if the director's research team upgrades a covered company. She does not participate in the analysis but approves the published report without disclosing her holding. The director most likely:
- Acomplies because she did not write the analysis.
- Bcomplies if the supplier position is profitable only after publication.
- Cviolates the conflict-disclosure duty because her beneficial interest could reasonably impair or appear to impair objectivity.
Check answer and explanation
Correct answer: C
Primary concept: Standard VI(A) requires full and fair disclosure of matters that could reasonably impair independence and objectivity or interfere with duties.
Decisive fact: The director approves research that may financially benefit her undisclosed personal holding.
Explanation: C is correct because approval authority and a related financial interest create a conflict that readers and the employer need to assess. A is wrong because the duty is not limited to the report's drafter. B is wrong because disclosure depends on the potential conflict, not on whether the position ultimately earns a profit after publication.
Question 121 · Module 10
A client instructs a portfolio manager to sell a thinly traded bond that the manager also owns personally. Which sequence most appropriately complies with transaction-priority requirements?
- ASubmit the client and personal sales together and allocate any executions equally between them.
- BGive the client's sale priority and enter the beneficial personal sale only afterward, subject to the firm's preclearance and dealing rules.
- CTransfer the personal bonds to an adult sibling and arrange for the sibling to sell before the client's order.
Check answer and explanation
Correct answer: B
Primary concept: Standard VI(B) gives client and employer transactions priority over transactions in which a member or candidate has beneficial ownership.
Decisive fact: The manager knows of a client instruction in an illiquid security and must not let a beneficial personal sale compete with or trade ahead of it.
Explanation: B is correct because the known client instruction must receive priority; any later personal transaction remains subject to the firm's preclearance, restricted-list, and execution procedures. A is incorrect because simultaneous submission and equal allocation can cause the manager's beneficial account to compete with the client for scarce liquidity. C is incorrect because an indirect transfer cannot be used to evade priority, and directing a related person's earlier sale would preserve the same misuse of client-order information.
Question 122 · Module 10
An adviser receives a fixed payment from a tax specialist for every referred client. The specialist is competent, and the referral does not increase the client's bill. The adviser should most appropriately:
- Aomit disclosure because the client suffers no direct additional charge.
- Bdisclose the nature and estimated value of the referral arrangement to the employer and affected clients or prospects.
- Cdisclose only after a referred client signs a contract with the specialist.
Check answer and explanation
Correct answer: B
Primary concept: Standard VI(C) requires appropriate disclosure of compensation, consideration, or benefits received for referrals.
Decisive fact: The fixed payment creates an incentive that may affect the adviser's recommendation even if the specialist is qualified and the bill is unchanged.
Explanation: B is correct because advance disclosure lets the employer and client evaluate the adviser's incentive and the full cost or benefit of the arrangement. A is wrong because a conflict can exist without a separately itemized client charge. C is wrong because disclosure after commitment is too late to inform the client's decision about whether to accept the referral.
Question 123 · Module 10
A candidate writes on a résumé, “Passed all three CFA exams and therefore guaranteed to receive the CFA charter next month.” She has not completed the required work-experience review. Which revision is most appropriate?
- AState factually that she passed the exams and is awaiting completion or approval of the remaining charter requirements.
- BRetain the statement because passing all examinations automatically grants the charter.
- CDescribe herself as “CFA, pending” because the abbreviation may be modified for candidates.
Check answer and explanation
Correct answer: A
Primary concept: Standard VII(B) permits factual statements about exam status but prohibits exaggerating or implying that partial completion confers the charter.
Decisive fact: Passing examinations alone does not complete every membership and charter requirement, so the guarantee is misleading.
Explanation: A is correct because it accurately distinguishes examination achievement from the remaining requirements. B is wrong because the charter is not granted solely by passing the exams. C is wrong because “CFA” is not a noun, a candidate title, or a designation that may be modified as “pending”; only those actually awarded the charter may use it as prescribed.
Question 124 · Module 10
After a Level I exam, a candidate tells a study group, “Several stand-alone questions focused on a specific named industry, and one answer required this exact formula.” The candidate does not reveal the wording of any question. The candidate most likely:
- Acomplies because only verbatim reproduction is prohibited.
- Bcomplies if every recipient is also registered for the CFA Program.
- Cviolates Standard VII(A) by disclosing confidential exam content and topic emphasis.
Check answer and explanation
Correct answer: C
Primary concept: Standard VII(A) prohibits conduct that compromises the integrity, validity, or security of CFA Institute programs, including disclosure of confidential exam content.
Decisive fact: The candidate communicates tested topics, emphasis, and solution information that could advantage future candidates.
Explanation: C is correct because confidentiality extends beyond exact question wording to specific tested content and examination details. A is wrong because paraphrased disclosure can still compromise exam integrity. B is wrong because sharing with other candidates is not an exception; it can increase the unfair advantage and the harm to the program.
Question 125 · Module 10
Which of the following is one of the six components of the CFA Institute Code of Ethics, rather than a requirement of a Standard of Professional Conduct?
- AGive transactions for clients and employers priority over transactions in which the member has a beneficial interest.
- BPromote the integrity and viability of the global capital markets for the ultimate benefit of society.
- CObtain written consent from all parties involved before accepting compensation that could create a conflict with the employer's interests.
Check answer and explanation
Correct answer: B
Primary concept: The Code states six broad commitments; the Standards turn them into specific, enforceable conduct requirements.
Decisive fact: Promoting the integrity and viability of the global capital markets is one of the six Code components, whereas transaction priority and written consent are conduct rules in Standards VI(B) and IV(B).
Explanation: B is correct because the commitment to the integrity and viability of the global capital markets, for the ultimate benefit of society, is the fifth of the Code's six components and is written at the Code's level of generality. A is wrong because giving client and employer transactions priority over beneficially owned transactions is the specific requirement of Standard VI(B). C is wrong because prior written consent from all parties for conflicting compensation is the specific requirement of Standard IV(B).
Question 126 · Module 10
An adviser learns that an elderly client suddenly wants to transfer nearly all assets to an unfamiliar online contact. The client appears confused, and the request conflicts with the investment policy. What is the adviser's most appropriate initial action?
- AFollow applicable law and firm procedures, pause or escalate where permitted, and seek to protect the client while preserving confidentiality.
- Bexecute immediately because any instruction from an account holder is automatically informed and suitable.
- Cdisclose the client's finances publicly to locate family members who can overrule the request.
Check answer and explanation
Correct answer: A
Primary concept: Duties of loyalty, suitability, competence, and confidentiality require careful handling of suspected diminished capacity or financial exploitation.
Decisive fact: The abrupt, concentrated transfer, confusion, and unfamiliar recipient are warning signs that require a controlled and legally informed response.
Explanation: A is correct because the adviser should use established escalation procedures, obtain compliance or legal guidance, and protect the client within applicable authority. B is wrong because warning signs and mandate conflict require investigation rather than blind execution. C is wrong because public disclosure is disproportionate and breaches confidentiality; any contact with trusted persons must follow law, authorization, and policy.
Question 127 · Module 10
An employer directs a research analyst to alter earnings estimates and conceal evidence of accounting fraud. The analyst refuses and is considering reporting the matter to regulators. Which statement is most accurate?
- AStandard IV(A) always prohibits reporting employer misconduct outside the firm.
- BProtecting clients and market integrity may justify whistleblowing, but the analyst should document the facts and obtain legal or compliance guidance.
- CThe analyst must obey until a court has entered a final judgment against the employer.
Check answer and explanation
Correct answer: B
Primary concept: The duty of loyalty to an employer does not require participation in illegal or unethical conduct and may yield when action protects clients or market integrity.
Decisive fact: Management is asking the analyst to conceal suspected fraud and publish analysis she knows is distorted.
Explanation: B is correct because the analyst should refuse, preserve evidence, follow internal escalation where effective, and seek legal advice regarding external reporting. A is wrong because Standard IV(A) does not shield employer wrongdoing or bar all whistleblowing. C is wrong because a professional need not continue known misconduct until litigation ends; dissociation and appropriate reporting may be required much earlier.
Question 128 · Module 10
An executive privately tells an analyst that a small experimental product has failed. The project represents 1% of current revenue, but public investors value the issuer largely on a 60% probability that the product will become its main business. The information is most likely:
- Aimmaterial because current revenue contribution is below 5%.
- Bpublic because investors already know the product is experimental.
- Cmaterial and nonpublic because both magnitude and probability, viewed in context, could affect an investment decision.
Check answer and explanation
Correct answer: C
Primary concept: Materiality under Standard II(A) depends on whether reasonable investors would consider information important, considering probability and magnitude in context.
Decisive fact: The failed product is central to market expectations and valuation despite its small contribution to current revenue.
Explanation: C is correct because a likely change to the issuer's expected future business can be price-sensitive even when a backward-looking percentage is small. A is wrong because no mechanical 5% threshold determines materiality. B is wrong because general public awareness of experimentation does not make the specific unannounced failure public.
Question 129 · Module 10
A firm posts a new “sell” recommendation to a public social-media account at noon but sends the same recommendation to advisory clients at 2 p.m., after the price has fallen. Which procedure would best support compliance?
- AContinue posting publicly first because a large audience makes the process fair.
- BEstablish a controlled dissemination sequence that gives clients a fair opportunity to receive and act on recommendations before or alongside public release.
- CStop using social media and communicate investment opinions only by postal mail.
Check answer and explanation
Correct answer: B
Primary concept: Standard III(B) requires policies that promote fair dissemination and a fair opportunity for clients to act on investment recommendations.
Decisive fact: The firm's chosen sequence predictably leaves advisory clients behind a price-moving public announcement.
Explanation: B is correct because the firm should coordinate channels, timing, approvals, and client notifications to avoid systematic disadvantage. A is wrong because broad public reach does not satisfy the specific duty owed to advisory clients. C is wrong because social media is not prohibited; it can be used when the firm applies a fair and controlled dissemination process.
Question 130 · Module 10
A client directs a manager to use a particular broker. The broker charges more than alternatives and has weaker execution, but the instruction is lawful. The manager should most appropriately:
- Aexplain the effect on best execution and seek written acknowledgement while continuing to act within the client's mandate and applicable rules.
- Bignore the instruction whenever another broker is cheaper.
- Caccept undisclosed rebates from the directed broker to offset the manager's inconvenience.
Check answer and explanation
Correct answer: A
Primary concept: Standard III(A) requires loyalty and care while recognizing that client-directed brokerage can limit the manager's ability to seek best execution.
Decisive fact: The client controls broker selection, but the manager must ensure the client understands the economic and execution consequences.
Explanation: A is correct because clear disclosure and documentation help the client make an informed direction and define the manager's constrained duty. B is wrong because unilaterally disregarding a lawful client instruction can breach the mandate. C is wrong because a secret personal rebate creates a conflict and does not compensate the client for poorer execution.
Question 131 · Module 10
A strategist relies on a respected external vendor's factor model. Before using it, she reviews the methodology, data coverage, assumptions, and historical limitations and independently tests several outputs. She may most appropriately:
- Anever rely on external research because Standard V(A) requires recreating every model from raw data.
- Brely on the vendor's reputation alone and omit her review from firm records.
- Cuse the model if her review establishes a reasonable basis and she continues to monitor material changes or limitations.
Check answer and explanation
Correct answer: C
Primary concept: Standard V(A) permits reliance on third-party research when a member makes reasonable and diligent efforts to evaluate its soundness.
Decisive fact: The strategist investigates the vendor's process and tests the model rather than accepting the product on reputation alone.
Explanation: C is correct because an informed review of assumptions, scope, data, and outputs can support reasonable reliance, with ongoing monitoring when circumstances change. A is wrong because independent recreation of every external model is not required. B is wrong because reputation alone is insufficient and the due-diligence basis should be documented and retained.
Question 132 · Module 10
A start-up adviser has only a short live track record. Its advertisement shows a simulated strategy return in the same font as actual client results and calls the combined series “our performance.” The most appropriate correction is to:
- Akeep the label if the simulation uses closing market prices.
- Bidentify simulated results prominently, explain material assumptions and limitations, and never blend them misleadingly with actual performance.
- Cremove all assumptions because detailed disclosure makes the advertisement too long.
Check answer and explanation
Correct answer: B
Primary concept: Standards I(C) and III(D) require hypothetical or simulated results to be presented in a manner that is not misleading and that distinguishes them from actual performance.
Decisive fact: The current label invites readers to mistake a back-test for returns actually earned for clients.
Explanation: B is correct because prominent identification and material assumptions allow prospects to evaluate the simulated evidence honestly. A is wrong because using real historical prices does not transform a hypothetical strategy into actual client performance. C is wrong because omitting assumptions would make the claim less, not more, understandable and could conceal model and implementation limitations.
Question 133 · Module 10
A technology vendor offers a portfolio manager valuable digital tokens if the manager introduces the vendor's analytics platform to her employer. She has authority to recommend vendors. Before accepting, she should most appropriately:
- Aaccept because non-cash digital assets are not compensation.
- Bdisclose the arrangement fully and obtain written consent from the employer before accepting the benefit.
- Caccept first and disclose only if the tokens later appreciate in value.
Check answer and explanation
Correct answer: B
Primary concept: Standards IV(B) and VI(A) apply to non-cash as well as cash benefits that may affect professional judgment or conflict with employer interests.
Decisive fact: The manager can influence vendor selection and would receive a valuable personal benefit for doing so.
Explanation: B is correct because the employer must evaluate and consent to the incentive before it is accepted, and the conflict must be managed. A is wrong because digital tokens can be consideration with economic value. C is wrong because the conflict arises when the benefit is offered and accepted, not only after a price increase; delayed disclosure cannot cure missing prior consent.
Question 134 · Module 10
A credit analyst is promoted to supervise a global research team. She is technically excellent but has never managed people or learned the firm's supervisory controls. To comply with Standard I(E), she should most appropriately:
- Adevelop the management and compliance competence required for the new role while ensuring qualified support during the transition.
- Brely solely on her credit credentials because technical competence covers every supervisory responsibility.
- Cwait for a subordinate violation before studying the control framework.
Check answer and explanation
Correct answer: A
Primary concept: Standard I(E) requires competence to evolve when professional responsibilities expand or change.
Decisive fact: The promotion adds people-management, oversight, and compliance responsibilities not demonstrated by the analyst's technical expertise.
Explanation: A is correct because she must obtain the role-specific knowledge, skills, and abilities needed to perform successfully and supervise reasonably. B is wrong because technical expertise does not automatically confer management or compliance competence. C is wrong because both competence and supervision are preventive duties; waiting for harm is inconsistent with maintaining the capability required for the position.
Question 135 · Module 10
A manager discovers that a data vendor introduced a coding error into valuations used in client reports. The error is material, and several reports have already been delivered. The manager should most appropriately:
- Aremain silent because the vendor, not the manager, created the error.
- Bcorrect only future reports because historical communications cannot be changed.
- Cinvestigate the scope, correct the analysis, notify affected recipients appropriately, and strengthen validation controls.
Check answer and explanation
Correct answer: C
Primary concept: Competence, reasonable basis, and fair client communication require professionals to respond promptly and transparently to material analytical errors.
Decisive fact: The manager now knows that a material error affected analysis already communicated to clients.
Explanation: C is correct because responsibility includes validating inputs, determining impact, correcting misleading information, and preventing recurrence. A is wrong because outsourcing data does not outsource the manager's professional duties. B is wrong because leaving affected clients with known material errors perpetuates the problem; appropriate correction of prior communications is necessary.
Question 136 · Module 10
A fund is marketed as excluding all thermal-coal issuers. Its mandate actually permits such holdings up to 10%, and the portfolio currently holds 6%. The manager most likely:
- Acomplies because the holding remains within the legal mandate.
- Bviolates the prohibition on misrepresentation because the absolute marketing claim conflicts with the actual strategy and holdings.
- Ccomplies if coal exposure improves risk-adjusted returns.
Check answer and explanation
Correct answer: B
Primary concept: Standard I(C) requires sustainability and other strategy claims to match the actual mandate, process, and portfolio rather than overstate exclusions or characteristics.
Decisive fact: The public claim promises zero exposure while the governing mandate permits, and the fund holds, thermal-coal issuers.
Explanation: B is correct because the marketing statement is factually inconsistent with both policy and implementation. A is wrong because legal and mandate compliance do not make a contradictory public claim truthful. C is wrong because strong performance cannot cure a false description of the strategy; the firm must correct the claim or align the portfolio and mandate with it.
Question 137 · Module 10
An oversubscribed initial public offering is suitable for several client accounts and for a manager's personal account. Under the firm's allocation policy, what is the most appropriate priority?
- AAllocate fairly among suitable client accounts before considering a beneficial personal allocation.
- BAllocate first to the manager because she identified the opportunity.
- CDivide equally among every account, including accounts for which the security is unsuitable.
Check answer and explanation
Correct answer: A
Primary concept: Standards III(B) and VI(B) require fair client allocation and priority for client transactions over beneficial personal transactions.
Decisive fact: Supply is limited, so a personal allocation could directly reduce the quantity available to suitable clients.
Explanation: A is correct because the manager must apply a documented fair allocation method to suitable clients and place their interests ahead of her own. B is wrong because sourcing the idea does not create personal priority. C is wrong because fair dealing does not require allocation to unsuitable accounts; suitability remains a threshold before a client participates.
Question 138 · Module 10
CFA Institute's Professional Conduct staff requests confidential client records relevant to an authorized investigation. Local law does not prohibit disclosure. The member should most appropriately:
- Arefuse because Standard III(E) has no exception for professional conduct investigations.
- Bcooperate with the authorized inquiry while protecting information from unrelated disclosure.
- Cpost the requested records publicly so the investigation is transparent.
Check answer and explanation
Correct answer: B
Primary concept: Standard III(E) does not prevent cooperation with an authorized CFA Institute Professional Conduct investigation, subject to applicable law.
Decisive fact: The request is relevant and authorized, and there is no conflicting legal prohibition on producing the records.
Explanation: B is correct because members must cooperate with the professional conduct process and limit use of confidential information to the proper inquiry. A is wrong because the guidance expressly recognizes this form of cooperation. C is wrong because cooperation is not a public-disclosure license; confidentiality continues to protect the records from unrelated audiences.
Question 139 · Module 10
A wealth manager tells a prospect, before engagement, that the manager will receive 0.25% of assets invested in a recommended private fund. The amount and duration are clear, and the employer has approved the arrangement. The manager most likely:
- Aviolates Standard VI(C) because referral compensation is always prohibited.
- Bviolates Standard III(B) because prospects may never receive conflict disclosures.
- Ccomplies with the referral-fee disclosure requirement if the disclosure remains complete, timely, and accurate.
Check answer and explanation
Correct answer: C
Primary concept: Standard VI(C) requires disclosure of referral consideration but does not categorically prohibit an appropriately disclosed and approved arrangement.
Decisive fact: The prospect receives specific information about the economic incentive before deciding whether to engage or invest.
Explanation: C is correct because timely disclosure of nature, value, and duration allows the prospect to evaluate the conflict. A is wrong because the Standard regulates disclosure rather than banning every referral payment. B is wrong because fair dealing does not prevent conflict disclosure to prospects; accurate advance disclosure is precisely what enables an informed decision.
Question 140 · Module 10
Which procedure most directly helps a firm prevent transaction-based market manipulation by its own traders?
- ASurveillance of order and cancellation patterns around the close and around benchmark fixings, with a documented economic purpose required for unusual orders.
- BRequiring every research report to carry a statement that past performance does not guarantee future results.
- CProhibiting staff from holding any security the firm covers, so that no personal trade can ever take place.
Check answer and explanation
Correct answer: A
Primary concept: Standard II(B) prohibits practices that distort prices or artificially inflate volume with the intent to mislead; prevention rests on controls that watch order patterns, timing and economic purpose.
Decisive fact: Transaction-based manipulation shows itself in orders without an economic purpose, so the control has to watch what is entered, cancelled and timed, not what is written in a disclaimer.
Explanation: A is correct because marking the close, layering and manufactured volume are visible in order and cancellation patterns, and requiring a documented economic purpose for unusual orders is what lets the firm separate legitimate trading from a manipulative signal. B is wrong because a performance disclaimer addresses how results are presented under Standards III(D) and V(B); it does nothing about the firm's own trading. C is wrong because the Standards do not require an absolute ban on personal holdings, such a ban addresses transaction priority under Standard VI(B) rather than manipulation, and it would not catch manipulative orders placed for the firm's own book.
Question 141 · Module 10
A supervisor allows staff to recommend securities through personal messaging accounts that the firm cannot archive or review. No violation has yet been reported. The supervisor should most appropriately:
- Acontinue because supervisory duties begin only after a substantiated complaint.
- Brequire approved, monitorable channels and implement training, review, and escalation controls before recommendations continue.
- Cask employees to delete messages weekly so private data cannot be inspected.
Check answer and explanation
Correct answer: B
Primary concept: Standard IV(C) requires reasonable systems to prevent and detect violations, including controls suited to the communication methods employees actually use.
Decisive fact: The supervisor knowingly permits an unmonitored channel that defeats review and record-retention procedures.
Explanation: B is correct because a reasonable supervisor must address the control gap proactively through approved systems and meaningful oversight. A is wrong because prevention and detection duties exist before a complaint. C is wrong because routine deletion would worsen record-retention and monitoring failures rather than create a compliant privacy safeguard.
Question 142 · Module 10
An asset owner gives a manager two tickets to a modest local event after a successful year. The gift comes from an existing client, the manager promptly discloses it to her employer, and firm policy permits acceptance. Which statement is most accurate?
- AEvery client gift must be rejected regardless of value, timing, disclosure, or policy.
- BThe gift is automatically prohibited because only prospective clients may provide benefits.
- CAcceptance may be permissible because a disclosed gift from an existing client is less likely to threaten objectivity, subject to employer policy and circumstances.
Check answer and explanation
Correct answer: C
Primary concept: Standard I(B) distinguishes benefits intended to influence independent judgment from appropriately disclosed client gifts, while requiring careful evaluation and employer controls.
Decisive fact: The benefit is modest, comes after service from an existing client, is disclosed promptly, and is allowed by policy.
Explanation: C is correct because those facts reduce, though do not eliminate, the threat to objectivity and allow the employer to manage it. A is wrong because the Standard does not impose a universal ban on every client gift. B is wrong because benefits from prospects often create greater influence concerns; the source being an existing client does not automatically prohibit acceptance.
Question 143 · Module 10
A member provides research in a jurisdiction that has no law governing analyst conflicts. Her firm also has no relevant policy. The Code and Standards nevertheless require conflict disclosure. She should:
- Aomit disclosure because the absence of law creates unrestricted discretion.
- Bcomply with the Code and Standards and disclose the conflict fully and fairly.
- Cwait until the jurisdiction enacts a conflict rule before changing the report.
Check answer and explanation
Correct answer: B
Primary concept: When no applicable law or regulation governs conduct, members and candidates must comply with the Code and Standards.
Decisive fact: The legal system is silent, but the professional conflict-disclosure obligation directly applies to the member.
Explanation: B is correct because absence of local regulation does not suspend the member's professional duties. A is wrong because a legal vacuum is not permission to ignore the Code and Standards. C is wrong because the obligation exists now; waiting for legislation would knowingly leave recipients without material information needed to assess objectivity.
Question 144 · Module 10
A firm has no legal record-retention period. An analyst documents interviews, model inputs, key assumptions, and the basis for each published recommendation. Which policy is most appropriate?
- ARetain the records for the period required by firm policy and, absent other guidance, follow the recommended professional retention practice rather than destroying them immediately.
- BDestroy the records after publication because a recommendation becomes self-supporting once distributed.
- CKeep only the final rating because underlying evidence is never relevant to later review.
Check answer and explanation
Correct answer: A
Primary concept: Standard V(C) requires records supporting investment decisions and communications; firms should establish a retention policy when law does not supply one.
Decisive fact: The interview notes, inputs, and assumptions are evidence of the analyst's reasonable basis and may be needed to reconstruct the decision.
Explanation: A is correct because meaningful supporting records must be preserved under applicable law and policy, with professional guidance filling gaps. B is wrong because distribution does not eliminate the need to demonstrate the research basis. C is wrong because a final rating alone cannot show what information, assumptions, and analysis supported the recommendation at the time.
Question 145 · Module 10
A manager advertises a gross return in a headline while placing fees and their material effect in an unreadable footnote. The numerical gross return is accurate. The presentation most likely:
- Acomplies because mathematical accuracy is the only requirement of Standard III(D).
- Bmay violate fair performance presentation because the format obscures information necessary to interpret the result.
- Ccomplies whenever at least one fee reference appears somewhere on the page.
Check answer and explanation
Correct answer: B
Primary concept: Standard III(D) requires performance communications to be fair, accurate, and complete in substance and presentation, not merely numerically correct.
Decisive fact: The design makes a material cost effect effectively invisible while emphasizing the more favorable gross result.
Explanation: B is correct because prominence, readability, and economic completeness affect whether a claim misleads. A is wrong because a correct gross number can still create a false impression when material fees are concealed. C is wrong because token disclosure is insufficient; information must be communicated in a manner an intended reader can reasonably notice and understand.
Question 146 · Module 10
A firm uses a generative-AI tool to draft issuer summaries. The tool invents a debt covenant, and an analyst publishes the summary without checking source documents. Which statement is most accurate?
- AThe tool alone is responsible, so no professional Standard applies to the analyst.
- BThe analyst complies if the vendor's terms call the tool “research grade.”
- CThe analyst remains responsible for competent use, verification, a reasonable basis, and correction of material errors.
Check answer and explanation
Correct answer: C
Primary concept: Standards I(E), V(A), and V(B) require professionals to understand tool limitations, verify material claims, and communicate reliable analysis.
Decisive fact: The analyst publishes an unsupported invented covenant without checking readily available primary documents.
Explanation: C is correct because automation does not transfer professional responsibility to the software vendor. A is wrong because the analyst selected and used the output in client-facing research. B is wrong because a marketing label cannot substitute for due diligence, source verification, appropriate human review, and transparent correction when an error is discovered.
Question 147 · Module 10
A manager uses client brokerage to buy investment research that directly assists management of the same client accounts, obtains competitive execution, and clearly discloses the arrangement. The practice is most likely:
- Apotentially consistent with the duty of loyalty if it benefits the clients and complies with applicable law and policy.
- Balways prohibited because brokerage commissions may purchase execution only.
- Cacceptable even if the research benefits solely the manager's personal portfolio.
Check answer and explanation
Correct answer: A
Primary concept: Standard III(A) permits brokerage arrangements that benefit the client when the manager seeks appropriate execution, makes required disclosure, and follows applicable rules.
Decisive fact: The research is used for the paying client accounts rather than for the manager or another party, and the arrangement is transparent.
Explanation: A is correct because client brokerage may obtain qualifying research that helps manage those clients, subject to best-execution and legal requirements. B is wrong because the Standard does not impose an absolute execution-only rule. C is wrong because a benefit solely for the manager would misuse client assets and violate loyalty even if the broker provides adequate execution.
Question 148 · Module 10
An analyst expects to resign in six weeks and is considering three steps toward a future advisory practice. Which step would most clearly cross the line from permissible preparation into disloyal competition before employment ends?
- ABuying generic scheduling software with personal funds for use after departure
- BExporting contacts from the employer's client system and inviting those clients to sign future advisory agreements
- CConsulting a lawyer on a weekend about licensing requirements for a business that has not begun operating
Check answer and explanation
Correct answer: B
Primary concept: Standard IV(A) generally permits preparations for independent practice while still employed but prohibits actual competition, solicitation, or misuse of employer property before departure.
Decisive fact: Soliciting current clients with confidential employer records is active competition and misuse of employer property, not mere planning.
Explanation: B is correct because taking confidential contacts and seeking commitments from current clients before departure combines misuse of employer property with active solicitation. A is incorrect because purchasing ordinary software privately for later use is generally a preparatory step, provided it does not interfere with current duties or violate an agreement. C is incorrect because obtaining legal advice about future licensing is also preparation rather than present competition, subject to applicable law and the analyst's employment contract.
Question 149 · Module 10
During an unscheduled examination break, a candidate checks a concealed phone for a formula and returns to the testing room without being noticed. The candidate does not use the formula on any answer. The conduct most likely:
- Acomplies because no answer was changed.
- Bcomplies if the formula concerned a topic not tested that day.
- Cviolates Standard VII(A) because attempting to obtain unauthorized assistance compromises examination integrity regardless of outcome.
Check answer and explanation
Correct answer: C
Primary concept: Standard VII(A) protects the integrity and security of CFA Institute programs and applies to prohibited conduct during examinations.
Decisive fact: The candidate intentionally accesses unauthorized material during the examination process, even though the attempt does not improve a recorded answer.
Explanation: C is correct because the prohibited act and threat to exam integrity do not depend on a successful score advantage. A is wrong because unchanged answers do not erase the attempt. B is wrong because candidates must follow testing rules for all unauthorized devices and materials; later relevance of the formula is not the controlling issue.
Question 150 · Module 10
A pension plan holds enough shares to influence a vote on a merger that would reduce beneficiary value. The manager routinely discards all proxy materials to save administrative cost. The manager should most appropriately:
- Aevaluate whether voting serves beneficiary interests and establish a policy for responsible voting rather than automatically discarding every proxy.
- Bvote according to the plan sponsor's executives even when their interests conflict with beneficiaries.
- Csell the shares before every vote because fiduciaries may never exercise ownership rights.
Check answer and explanation
Correct answer: A
Primary concept: Standard III(A) treats proxy voting and other ownership rights as client assets that should be exercised prudently when doing so is in the client's best interest.
Decisive fact: The vote may materially affect beneficiary value, so automatic non-voting is not a reasoned cost-benefit decision.
Explanation: A is correct because the manager should assess materiality, costs, and beneficiary interests under a documented policy. B is wrong because beneficiaries, not conflicted sponsor executives, are the relevant clients. C is wrong because fiduciaries are not prohibited from voting; responsible exercise of ownership rights can be an important part of loyalty and care.
Question 151 · Module 10
A research firm receives undisclosed issuer fees, allows analysts to trade ahead of reports, and labels every report “independent.” The analysis itself is carefully calculated. Which response best addresses the ethical failures?
- AKeep the label because analytical accuracy neutralizes conflicts and transaction priority.
- Bdisclose and manage issuer compensation, enforce client-first personal-trading controls, and describe the research process truthfully.
- Cretain current practices but add a statement that investments can lose value.
Check answer and explanation
Correct answer: B
Primary concept: Standards I(B), I(C), VI(A), and VI(B) jointly require independence safeguards, truthful description, conflict disclosure, and priority for client transactions.
Decisive fact: Undisclosed issuer incentives, front-running opportunity, and a false independence claim create distinct harms that accurate calculations do not cure.
Explanation: B is correct because each failure needs a targeted control: transparent compensation, restricted and monitored personal trading, and accurate communications. A is wrong because sound arithmetic does not remove biased incentives or unfair priority. C is wrong because generic risk language says nothing about the firm's conflicts, trading practices, or misleading independence claim.
Question 152 · Module 10
The CFA Institute Professional Conduct Program may begin an investigation on the basis of:
- Aa written complaint, a self-disclosure on the annual conduct statement, media reports, or an exam-conduct report
- Ba written complaint from a client only
- Ca court conviction only
Check answer and explanation
Correct answer: A
Primary concept: How professional-conduct enforcement works
Decisive fact: Inquiries may be opened from several sources, not only from a client complaint.
Explanation: A is correct because the Professional Conduct Program may act on complaints, self-disclosures made on the annual Professional Conduct Statement, information in the public domain, and reports arising from exam administration. B is wrong because limiting the source to clients would leave most misconduct undetected. C is wrong because a conviction is one possible trigger among several and is not a precondition.
Question 153 · Module 10
After an investigation, a member who does not accept the Designated Officer's proposed sanction is entitled to:
- Aan automatic appeal to a national regulator
- Ba hearing before a panel of CFA Institute members
- Cimmediate reinstatement pending review
Check answer and explanation
Correct answer: B
Primary concept: Enforcement outcomes
Decisive fact: The disciplinary process provides for a panel hearing when a proposed sanction is rejected.
Explanation: A is wrong because CFA Institute discipline is a membership matter and does not route to a regulator. B is correct because a member may reject the proposed sanction and request a hearing before a panel of members and charterholders. C is wrong because rejecting a sanction does not suspend the process or restore standing.
Question 154 · Module 10
Sanctions available under the Professional Conduct Program include:
- Acriminal penalties and fines payable to clients
- Bmandatory restitution enforced by a court
- Ca private censure, suspension of membership and use of the designation, or revocation
Check answer and explanation
Correct answer: C
Primary concept: Range of sanctions
Decisive fact: CFA Institute sanctions affect membership and the right to use the designation.
Explanation: A is wrong because criminal penalties are imposed by public authorities, not by a professional body. B is wrong because restitution is a legal remedy outside the programme's powers. C is correct because the available outcomes range from a private censure through suspension to revocation of membership and of the right to use the CFA designation.
Question 155 · Module 10
When the Code and Standards are stricter than local law, a member must:
- Afollow the stricter Code and Standards
- Bfollow local law because it is legally binding
- Cfollow whichever standard the employer selects
Check answer and explanation
Correct answer: A
Primary concept: Applicable law and the Code
Decisive fact: The governing rule is the stricter of applicable law and the Code and Standards.
Explanation: A is correct because Standard One A requires members to comply with the more strict of the applicable law or the Code and Standards. B is wrong because compliance with a weaker local law does not discharge the professional obligation. C is wrong because the choice does not belong to the employer.
Question 156 · Module 10
An integrated case describes an analyst who leaves a firm, takes a client list, and later posts performance claims on social media. The most efficient method is to:
- Aselect the single most serious Standard and answer only on that
- Bidentify each duty separately, test the decisive fact for each, and then state the required action
- Cconclude that all conduct after resignation is outside the Standards
Check answer and explanation
Correct answer: B
Primary concept: The evidence-led method for an integrated case
Decisive fact: An integrated case usually engages several Standards, each with its own decisive fact.
Explanation: A is wrong because an integrated case is designed to test more than one duty. B is correct because separating the duties, and matching each to the fact that activates it, produces a complete and defensible answer. C is wrong because duties to a former employer and duties on communication continue after resignation.
Question 157 · Module 10
In an integrated case, the most reliable way to eliminate a distractor option is to ask whether it:
- Auses language that sounds less severe
- Brefers to a Standard not covered in the reading
- Csolves a different ethical problem from the one the facts create
Check answer and explanation
Correct answer: C
Primary concept: Eliminating wrong answers
Decisive fact: A distractor commonly states a true principle that the facts do not engage.
Explanation: A is wrong because severity of wording is not evidence. B is wrong because all seven Standards are examinable. C is correct because the frequent trap is an option that is correct in general but responds to a duty the facts never trigger.
Question 158 · Module 10
The 2024 revision of the Code and Standards is best described as:
- Aa targeted update that clarified specific obligations rather than a rewrite of the framework
- Ba complete replacement of the seven Standards
- Ca removal of the requirement to comply with applicable law
Check answer and explanation
Correct answer: A
Primary concept: The current Standards include three 2024 changes
Decisive fact: The structure of the Code and the seven Standards was retained; specific provisions were clarified.
Explanation: A is correct because the revision refined particular obligations while leaving the Code's six components and the seven Standards in place. B is wrong because the seven Standards remain. C is wrong because the duty to comply with applicable law is unchanged and central.
Question 159 · Module 10
A candidate preparing for the 2027 exam finds that a curriculum reading differs from the published errata. The candidate should:
- Afollow the original reading, which was reviewed first
- Bfollow the errata, which supersedes the original reading
- Cask an employer which version to use
Check answer and explanation
Correct answer: B
Primary concept: Current changes, 2027 errata and exam scope
Decisive fact: Errata are issued precisely to correct the published curriculum.
Explanation: A is wrong because the errata exists because the original was incorrect. B is correct because the errata notice states the corrected position and takes precedence over the original text. C is wrong because exam scope is set by CFA Institute, not by an employer.
Question 160 · Module 10
In the Handbook's distinction between mandatory duties and recommended compliance procedures, 'must' and 'should' are best distinguished as:
- Atwo words for the same obligation
- Ba distinction that applies only to Standard Seven
- Ca required action against recommended best practice
Check answer and explanation
Correct answer: C
Primary concept: Final distinctions and action words
Decisive fact: Only a required action can be the basis of a violation.
Explanation: A is wrong because treating them alike produces answers that over-state what the Standards require. B is wrong because the distinction runs throughout the Standards. C is correct because 'must' states an obligation whose breach is a violation, while 'should' identifies recommended procedure that strengthens compliance.
Question 161 · Module 10
A member is asked for a one-sentence defence of an answer in an ethics case. The strongest structure is:
- Aname the Standard, state the decisive fact, and state the required action
- Bdescribe the member's intentions in detail
- Clist every Standard that might be relevant
Check answer and explanation
Correct answer: A
Primary concept: The one-minute Ethics algorithm
Decisive fact: A defensible answer connects a rule to a fact to an action.
Explanation: A is correct because that structure demonstrates the rule, the trigger and the consequence in a form a grader or a supervisor can verify. B is wrong because intentions alone do not connect the conduct to the applicable rule; where intent is a required element, it must also be tested against the facts. C is wrong because listing possibilities without resolving them is not a conclusion.
Question 162 · Module 10
An analyst uses an artificial intelligence tool to draft a recommendation and publishes it without verifying the output. The most likely violation concerns:
- Afair dealing among clients
- Bdiligence and reasonable basis
- Cpreservation of confidentiality
Check answer and explanation
Correct answer: B
Primary concept: Technology and diligence
Decisive fact: The duty to have a reasonable and adequate basis rests on the member, not on the tool.
Explanation: A is wrong because nothing in the facts concerns unequal treatment of clients. B is correct because Standard Five A requires diligence and a reasonable basis, and delegating that to an unverified tool does not discharge it. C is wrong because no client information has been disclosed.
Question 163 · Module 10
A member discovers that a colleague has been rounding composite returns upward for two years. The member's most appropriate response is to:
- Acorrect the figures privately and say nothing
- Bwait until the annual audit raises the issue
- Craise the conduct with a supervisor or compliance, seek correction, and cease any participation in continuing misconduct
Check answer and explanation
Correct answer: C
Primary concept: Dissociation and reporting
Decisive fact: A member must avoid participation in continuing violations and dissociate effectively; escalation is a recommended route to correction.
Explanation: A is wrong because silently changing figures does not address the continuing practice or establish effective dissociation. B is wrong because waiting allows continued association with known misconduct. C is correct because seeking correction through a supervisor or compliance is a recommended intermediate step, while ceasing participation and dissociating effectively are required if the violation continues. Reporting alone does not discharge that duty.
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These independently written questions and slides are educational resources from JS Insights. They are not official CFA Institute curriculum materials or examination questions. Candidates should use the current official curriculum, topic outline and errata as the authoritative sources.