Carter Pewterschmidt, CFA is the CEO of a boutique asset management firm, Shallow & Pedantic Capital, which follows the CFA Code of Ethics & Standards of Professional Conduct. One day, he is notified by an analyst, Peter Griffin, about a potential violation within Shallow & Pedantic's market-making department.
Griffin tells Pewterschmidt that Glen Quagmire, the head market maker, overheard a conversation in the ladies restroom between the CEO of Pawtucket Brewery and a managing director of the investment banking department of Shallow & Pedantic. The conversation was material and nonpublic, and Quagmire made the appropriate disclosures to his immediate supervisors and Chief Compliance Officer.
Pewterschmidt calls both Griffin and Quagmire into his office to discuss whether the any violations of the code occurred.
Quagmire: "Shallow & Pedantic should not entirely prohibit proprietary trading when in possession of material nonpublic information. Giggity."
Griffin: "The CFA Code of Ethics strictly prohibits trading activities, including proprietary trading, based on material nonpublic information. However, it is acceptable when non-material nonpublic information is acquired through the mosaic theory.
According to the Code, who is right?
1) Both are incorrect.
2) Quagmire only.
3) Griffin only.
4) Both are correct. |
发表于 2011-7-13 16:31
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