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The Folly Of Material Non-Public Info

How in the hell would the housekeeper know that the conversation was about a tender offer?!? She merely saw them talking, didnt hear anything, and even if she did, she is NO way a credible source.... What do you guys think??


A stockbroker who is a member of CFA Institute has a part-time housekeeper who also works for the CEO of Festival, Inc. One day the housekeeper mentions to the broker that she saw the CEO of Festival having a conversation at his home with John Tater, who is a nationally known corporate lawyer and consultant. The stockbroker is restricted from trading on this information:

A) if the housekeeper says the meeting concerned a tender offer and the broker knows that it is non-public information.

B) for both of the reasons listed here.

C) only if the broker knows that the meeting is non-public information.


Your answer: C was incorrect. The correct answer was A) if the housekeeper says the meeting concerned a tender offer and the broker knows that it is non-public information.

Standard II(A), Material Nonpublic Information, states “a member cannot trade or cause others to trade in a security while the member possesses material nonpublic information” A tender offer would certainly be material nonpublic information. Knowing that the meeting took place, and nothing else, does not restrict the broker. A reasonable investor would need to know more to determine if the information was material.

some of the questions here seem to be the reasons no one has ever gotten 100% on this test.

I would have said B, especially since answer A contains answer C.

If she says she saw them together(heard nothing) and then the broker looks through the news for clues and analyzes the financials discovering that there could be a tender offer coming...is that mosaic theory, or tainted because the first meeting was in private?

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