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Regarding non-public information, which one of the following statements is NOT correct?
A)
An analyst may use some types of non-public information.
B)
Disclosing material non-public information would have an impact on the price of a security or be of interest to a reasonable investor.
C)
A member can be summarily suspended for having received material non-public information.



All of these are true except that a member can be suspended for having received material non-public information. The member can receive such information as part of their regular duties or by accident. Neither is punishable in and of itself, and penalties only apply if the member trades or causes others to trade on the information. The member may have certain duties, such as trying to disseminate the information after receiving it. An analyst may use nonmaterial non-public information.

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Insider trading can be defined as information that is:
A)
material and public.
B)
material and nonpublic.
C)
nonmaterial and nonpublic.



Information is material if it would be important to the investor in their investment making decision. Information is nonpublic if it is not yet available to the public.

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Which one of the following least accurately describes the CFA Institute Standard about using material nonpublic information?
A)
An analyst may use nonmaterial nonpublic information as long as it has been developed under the Mosaic Theory.
B)
An analyst may violate this Standard by passing information to others even when it has been obtained from outside the company.
C)
An analyst using material nonpublic information may be fined by CFA Institute.



There is no provision for CFA Institute to issue fines to members. Members may not use material nonpublic information for trading purposes. Nonmaterial, nonpublic information may be used together with analysis of public information under the Mosaic Theory.

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According to CFA Institute Standards of Professional Conduct, which of the following statements about material nonpublic information is NOT correct? Information is:
A)
material if reasonable investors would want to know the information before making an investment decision.
B)
nonpublic until it has been disseminated to a select group of investors.
C)
nonpublic until it has been disseminated to the marketplace in general.



Standard II(A), Material Nonpublic Information, states that information is “nonpublic” until it has been disseminated to the marketplace in general as opposed to a select group of investors.

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Don Benjamin, CFA, is the compliance officer for a large brokerage firm. He wants to prevent the communication of material nonpublic information and other sensitive information from his firm’s investment banking and corporate finance departments to its sales and research departments. The most common and widespread approach that Benjamin can use to prevent insider trading by employees is the:
A)
fire wall.
B)
Wall Street Rule.
C)
legal list.



To comply with Standard II(A), a fire wall provides an information barrier that prevents communication of material nonpublic information and other sensitive information from one department to another within a firm.

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A brokerage firm has a trading department and an investment-banking department. Often the investment-banking department receives material non-public information that would be valuable in advising the firm’s brokerage clients. In order to comply with the Standards, the firm:
A)
should record the exchange of information between the investment-banking department and the brokerage department.
B)
must divest one of the departments.
C)
should restrict employee trading in securities for which the firm is in possession of material non-public information.



Restricting employee trading in stocks for which the firm has material non-public information is the best answer. Recording the exchange of information between the two departments is not the best option because there should be no exchange of information between these two departments. Divesting a department is not a suitable method for addressing this potential problem.

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A CFO who is a CFA Institute member is careful to make his press releases—some of them containing material and previously undisclosed information—clear and understandable to his readers. While writing a new release, he often has his current intern proofread rough drafts. He also sends electronic copies to his brother, an English teacher, to get suggestions concerning style and grammar. With respect to Standard II(A), Material Nonpublic Information, the CFO is:
A)
not in violation of the Standard.
B)
only in violation by e-mailing the pre-release version to his brother but not the intern, because the intern is in essence an employee of the firm.
C)
violating the standard by either showing the pre-release version to his intern or sending it to his brother.



Standard II(A), Material Nonpublic Information, says that a member must be careful about handling material non-public information. As a member of CFA Institute, the CFO must limit the people who see important information before it is released. It would not be appropriate to involve an intern or a relative in the process.

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Steve Waters, a CFA Level I candidate, has decided to enter into a long position of Farmco stock. Since Farmco is thinly traded, Waters is concerned the order will overwhelm the liquidity of Farmco and the price will surge. Waters engages in a series of block trades in order to accomplish the purchase. According to Standard II(B), Market Manipulation, Waters has engaged in:
A)
neither transaction-based manipulation nor information-based manipulation.
B)
transaction-based manipulation, but not information-based manipulation.
C)
both transaction-based manipulation and information-based manipulation.



Waters is not in violation of Standard II(B), Market Manipulation. Transaction-based manipulation includes, but is not limited to, transactions that artificially distort prices or volume. Information-based manipulation includes, but is not limited to, spreading false rumors about a firm in order to induce others to trade.

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All of the following are violations of Standard II(B) Market Manipulation EXCEPT:
A)
securing a controlling interest in an equity security in order to influence the price of a related derivative instrument.
B)
disseminating misleading information about the development of new products and technologies.
C)
exploiting differences in market inefficiencies.



Standard II(B) Market Manipulation prohibits practices that distort prices or artificially inflate trading volumes with the intent to mislead market participants. The Standard is not intended to prohibit legitimate trading strategies that exploit differences in market inefficiencies.

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Mark Williamson is “bearish” on ABC Manufacturing Company. Williamson is so convinced that ABC is overpriced, two weeks ago, he shorted 100,000 shares. Today, Williamson is “surfing” several popular investment bulletin boards on the internet and posting false derogatory comments about company management. According to Standard II(B), Market Manipulation, Williamson has engaged in:
A)
transaction-based manipulation, but not information-based manipulation.
B)
both transaction-based manipulation and information-based manipulation.
C)
information-based manipulation, but not transaction-based manipulation.



Williamson is in violation of Standard II(B), Market Manipulation, by engaging in information-based manipulation. Information-based manipulation includes, but is not limited to, spreading false rumors about a firm in order to induce others to trade.

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