Questions 1 to 6 relate to Ethical and Professional Standards
David Seaman, CFA, Case Scenario
David Seaman, CFA, is a portfolio manager at Himalayan Wealth Management, an asset
advisory firm, where he is responsible for managing the accounts of high net-worth
clients. He has categorized the accounts being managed as high risk tolerance/low
liquidity needs (Class A); high risk tolerance/high liquidity needs (Class B); low risk
tolerance/low liquidity needs (Class C); and low risk tolerance/high liquidity needs (Class
D). HWM portfolio managers are under strict orders to comply with the CFA Institute
Code of Ethics and Standards of Professional Conduct.
Seaman has hired Martin Freeman as a junior portfolio manager. Freeman has passed the
CFA Level II exam this year but will not be sitting for the Level III exam because he has
missed the fee payment deadline. After joining HWM, Fraser distributes business cards to
his colleagues at his previous employer as well as his current business contacts. His
business card reads as follows:
Himalayan Wealth Management
Martin Fraser
Junior Portfolio Manager
CFA Program Level III Candidate
Seaman has also recently changed the broker used to execute client trades. Eastern
Associates (EA), a brokerage-dealer firm, will now be executing HWM client trades. EA
has appointed Sylvia Marshall to broker the trades. On behalf of EA, Marshall will be
charging a fee higher than the previous broker but promises to deliver exemplary
performance results. EA is relatively new to the market and does not have a performance
history.
Unbeknownst to clients, Marshall is Seaman’s close friend and upon mutual consent has
offered to reduce broker fees below the standard rate. In exchange she would like Seaman
to provide investment advice for her personal portfolio and her wealthiest brokerage
clients. Marshall discloses this arrangement to her supervisor while Seaman accepts the
Marshall notifies Seaman that Blue-Cap Enterprises, a robotic chip manufacturer and her
brokerage client, will soon undertake an IPO of its stock. The news has not yet been
made public and, in a meeting, Marshall informally tells Seaman that she came to know
of this impending event while overhearing a conversation between two senior brokers at
EA. Upon the conclusion of their meeting, Seaman returns to his desk and instructs
Fraser to keep the news to himself and allocate the stock to client portfolios. Fraser
allocates the stock to Class A and B while he deems the event as highly risky for the
other two classes and makes no further allocations.
At the end of first year of engaging EA, Seaman prepares a performance presentation
which summarizes the results achieved and projections for the future. The respective
statements to be included in the presentation are as follows:
Results achieved: ‘HWM has generated an annual return of 18.2% on Class A accounts;
15.2% on Class B accounts; 8.6% on Class C accounts; and 6.1% on Class D accounts.’
Projections: ‘We expect to maintain or enhance the results achieved in the current year
for the foreseeable future subject to tax rates and fees remaining constant. We do not seek
to guarantee performance results.’
1. By distributing his business card, Fraser is in violation of the CFA Institute
Standards of Professional Conduct because he most likely:
A. shared them with his former colleagues.
B. specified his candidacy in the CFA Program.
C. has not identified himself as a Level II candidate.
2. By selecting EA as a brokerage firm, Seaman is in violation of the CFA Institute
Standards of Professional Conduct relating to:
A. suitability.
B. fair dealing.
C. loyalty, prudence and care.
3. In context of the details of the brokerage arrangement with Marshall, which of the
following Standards of Professional Conduct is least likely being violated?
A. Referral fees
B. Conflict of interests
C. Additional compensation arrangements
4. Are the three individuals in violation of the CFA Institute Standards of
Professional Conduct with respect to the IPO trade?
Marshall? Seaman? Fraser?
A. Yes No No
B. Yes Yes No
C. Yes Yes Yes
5. Is the ‘Results Achieved’ statement consistent with the CFA Institute Standards of
Professional Conduct?
A. Yes.
B. No, returns have not been identified as being either gross- or net-of fees.
C. No, the statement highlights discrimination of client classes in terms of
differing portfolio results.
6. Is the ‘Projection’ statement consistent with the CFA Institute Standards of
B. No, past results are being simulated.
C. No, there is an implicit performance guarantee.
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