答案和详解如下： Q16. Carmen Jorgensen, CFA, is the chief compliance officer for Dalton Financial Network, a regional brokerage firm. Dalton is divided into three regions, each of which has a regional compliance officer. Martin Lund, CFA, is the regional compliance officer for Dalton’s South Region. Dalton has established procedures for proper allocation of trades to all clients. In October, Fred Curry, CFA, a broker in the South Region, misallocated a trade in favor of certain of his clients and to the detriment of others. It became evident that Lund had failed to review the trades on a timely basis as called for in Dalton’s Procedures Manual. After an investigation, it was concluded that Curry violated the Code and Standards by failing to allocate trades properly and Lund violated the Code and Standards by failing to supervise appropriately. It should also conclude that Jorgensen: A) did not violate the Code and Standards because adequate procedures were in place, even though they weren't being followed. B) violated the Code and Standards by failing to establish proper procedures. C) violated the Code and Standards by failing to adequately supervise her regional compliance officer, Lund. Correct answer is C) Standard IV(C) is violated when a supervisor does not take reasonable steps to implement an effective compliance system. Even though the system employed by Dalton may be adequate, Jorgensen is responsible to see that her regional compliance officers follow it.
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发表于 2009-1-4 16:10
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