3. Ralph Malone, CFA, is an investment advisor at a multinational fiance corporation. He has many welthy individuals among his client base, including atrust account that benefits three of his immediate family members as well aw himself.The research department of Malone's firm issues a buy recommendation on a stock that would be a suitable investment for several client accounts, including the family trust account. Which of the following would be considered a violation of Standard VI-B Priority of Transactions

A. Malone trades for his clients' accounts before the release of material nonpublic information

B. Malone trades on the family account immendiately after his firm's clients have been informed of the buy recommendaiton

C Malone waits to trade on the family account until four days ater his firm's clinets have been informed buy recommendation.

D. Malone buys stock for a client's account after the stock is put on the firm's recommended buy list but before this information is made public.

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D是不是违反了fair dealing 和priority of transaction? 因为recommendation还没有公布，另一部分client还不知情的情况下你就已经交易了。

C是不是也违反了fair dealing? 因为他family的trust的那个account，也是他的client。。居然等公布了4天之后交易，显失公平。

B似乎没有任何问题。

A显然就是乱说话，，违反了实质性非公开信息。material nonpublic information.

大家看我分析得对吗？

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但是这题的答案是B...匪夷所思  + +

答案应该没错，因为问题问的是哪一个违反了Priority of Transactions，并没有说其他的选项就一定没有违反standard.

b 明显违反了Priority of Transactions，所有的clients应该同等对待。

a 应该是nonpublic information  不违反Priority of Transactions

c 你说得没错

d 我觉得没有什么问题，只要这个recommendation不包含nonpublic information就可以了，他只对自己的clients负责。

答案显然是B，因为四个答案都违反了CODE AND ETHIC，但是只有B是违反了priority of transaction, 因为Ralph并非只管理了这个trust account, 他不应该只处理这个账户在即使所有客户都接到通知后， 而应对他管理的所有account进行同时处理（题中也说了是several client accounts了）。

（道德手册上P122）

VI- confilicts of interest B proiority of transcactions

有这样一句话：

Family accounts that are client accounts should be treated like any other firm account and should neither be given special treatment nor be disadvantaged because of an exisintng family relationship with the account, however, the member or candidate may still be subject to pre-clearance or reporting requirements of their employer or applicable law.

C选项将家庭成员受益的帐户，同时也是公司的客户的帐户，过了n多天再交易，是不是be disadvantaged because of an exisintng family relationship with the account？

能不能解释一下，为什么C不违反 VI-B?

楼上似乎漏抄了一句话：If a member or candidate has a beneficial ownership in the account,however, the member of candidate may still be subject to pre-clearance or reporting requirements of their employer or applicable law.

因为本题中说道：“including a trust account that benefits three of his immediate family members as well aw himself.” 所以他在进行买卖之前必须要提前报批才行，不能自行买卖。

也许C的意思是，等的这四天是在等待批准。。。

may still be subject to pre-clearance or reporting requirements of their employer or applicable law.

我看见这句话了。可是这里用的情态动词是may.. 是可能而非必需。。。

会员与candidate可能被要求提前清仓或申报

但是是of their employer or applicable law.

不是of Standards of Practise.