Q14. Sally Watson works as an equity portfolio manager for Brunswick Investment Advisers (BIA). Wally Jackson, President and Chief Investment Officer of the firm, is a CFA charterholder who supervises Watson and other investment professionals within the firm. Watson is a candidate in the CFA Program, and she has recently passed the Level II exam. BIA's clients include trusts, foundations, endowments, corporations, and high net worth individuals, including accounts for family and friends of its employees. Jackson and Watson manage client portfolios with a growth strategy and concentrate on holdings in the healthcare, technology, and communications sectors. About 10 percent of BIA accounts are actively managed.

Because BIA uses Accommodate Broker Dealer for executing transactions, Accommodate provides research to BIA regarding holdings in accounts that are actively managed. The fees Accommodate charges BIA competitive, and BIA applies the same basic fee structure to all its clients. BIA’s clients do not know about BIA’s arrangement to get research information from Accommodate.

The clients do know that Accommodate routinely allocates shares in IPOs that it underwrites to BIA. Jackson is eagerly awaiting the IPO of a new technology company that he intends to allocate across all current portfolios, including the proprietary account and accounts of friends and family. Based upon his research, Jackson feels this IPO has good potential and has been working to get an unusually large number of shares of the IPO.

BIA has recently been awarded two new client accounts, totaling $100 million, which are in the process of completing transitions from other managers. Although an investment objective and guidelines have not been formalized for the accounts, Jackson allocates shares of the IPO across all client accounts on a pro rata basis, including an allocation for these new client accounts. 

Watson serves on the board of directors for New Medical Developments, a biotech firm in which she maintains significant stock and options. BIA owns 4.5 percent of New Medical’s stock on behalf of its clients. At a special meeting of New Medical’s board, Watson learns that Remedy Inc. is preparing a confidential tender offer for all of New Medical’s shares outstanding. After the meeting, Watson sends an electronic mail message to Jackson detailing the offer.

Jackson immediately places New Medical Developments on BIA’s restricted list so representatives of BIA cannot recommend the stock. As rumors circulate in the investment community about the tender offer, some of Jackson’s clients call and ask him to look into the possibility of purchasing stock in New Medical Developments. Jackson is fearful of his situation and puts off such requests. As a result, one client, Craig Mills, files a complaint with CFA Institute that Jackson is not responding to his requests. Knowing the precarious situation he is in, Jackson decides to wait until the tender offer has been announced to address Mills’ complaint.

CFA Institute becomes suspicious of Mills, because he seems to have a history of trading stocks for which material information soon becomes public. As part of an investigation into possible insider trading activities, CFA Institute asks Jackson to furnish CFA Institute with Mills’ trading history.

Watson must notify BIA of all the following EXCEPT:

A)   her ownership of the stock in New Medical Developments.

B)   any independent consulting work she performs for third parties.

C)   her plans for taking the next CFA exam.

Q15. With respect to the arrangement that BIA has with Accommodate, based on the provided information:

A)   no violation has occurred as long as BIA informs CFA Institute that the firm receives research information from the brokerage firm.

B)   no violation has occurred since BIA charges the fee structure to all of its clients.

C)   a violation has occurred because BIA charges the same fee structure to all of its clients.

答案和详解如下：

Q14. Sally Watson works as an equity portfolio manager for Brunswick Investment Advisers (BIA). Wally Jackson, President and Chief Investment Officer of the firm, is a CFA charterholder who supervises Watson and other investment professionals within the firm. Watson is a candidate in the CFA Program, and she has recently passed the Level II exam. BIA's clients include trusts, foundations, endowments, corporations, and high net worth individuals, including accounts for family and friends of its employees. Jackson and Watson manage client portfolios with a growth strategy and concentrate on holdings in the healthcare, technology, and communications sectors. About 10 percent of BIA accounts are actively managed.

Because BIA uses Accommodate Broker Dealer for executing transactions, Accommodate provides research to BIA regarding holdings in accounts that are actively managed. The fees Accommodate charges BIA competitive, and BIA applies the same basic fee structure to all its clients. BIA’s clients do not know about BIA’s arrangement to get research information from Accommodate.

The clients do know that Accommodate routinely allocates shares in IPOs that it underwrites to BIA. Jackson is eagerly awaiting the IPO of a new technology company that he intends to allocate across all current portfolios, including the proprietary account and accounts of friends and family. Based upon his research, Jackson feels this IPO has good potential and has been working to get an unusually large number of shares of the IPO.

BIA has recently been awarded two new client accounts, totaling $100 million, which are in the process of completing transitions from other managers. Although an investment objective and guidelines have not been formalized for the accounts, Jackson allocates shares of the IPO across all client accounts on a pro rata basis, including an allocation for these new client accounts. 

Watson serves on the board of directors for New Medical Developments, a biotech firm in which she maintains significant stock and options. BIA owns 4.5 percent of New Medical’s stock on behalf of its clients. At a special meeting of New Medical’s board, Watson learns that Remedy Inc. is preparing a confidential tender offer for all of New Medical’s shares outstanding. After the meeting, Watson sends an electronic mail message to Jackson detailing the offer.

Jackson immediately places New Medical Developments on BIA’s restricted list so representatives of BIA cannot recommend the stock. As rumors circulate in the investment community about the tender offer, some of Jackson’s clients call and ask him to look into the possibility of purchasing stock in New Medical Developments. Jackson is fearful of his situation and puts off such requests. As a result, one client, Craig Mills, files a complaint with CFA Institute that Jackson is not responding to his requests. Knowing the precarious situation he is in, Jackson decides to wait until the tender offer has been announced to address Mills’ complaint.

CFA Institute becomes suspicious of Mills, because he seems to have a history of trading stocks for which material information soon becomes public. As part of an investigation into possible insider trading activities, CFA Institute asks Jackson to furnish CFA Institute with Mills’ trading history.

Watson must notify BIA of all the following EXCEPT:

A)   her ownership of the stock in New Medical Developments.

B)   any independent consulting work she performs for third parties.

C)   her plans for taking the next CFA exam.

Correct answer is C)         

Watson does not have to inform BIA about her plans to take a CFA exam. She should be careful, of course, not to misinform BIA of her plans, i.e., say she will when she knows she cannot. All of the other notifications are required. Standard VI(A) requires her to inform BIA about potential conflicts of interest. Standard IV(A) requires her to inform BIA about any consulting work she performs.

Q15. With respect to the arrangement that BIA has with Accommodate, based on the provided information:

A)   no violation has occurred as long as BIA informs CFA Institute that the firm receives research information from the brokerage firm.

B)   no violation has occurred since BIA charges the fee structure to all of its clients.

C)   a violation has occurred because BIA charges the same fee structure to all of its clients.

Correct answer is C)         

Watson has violated the Soft Dollar Standard. For directing the trades through a given brokerage firm, BIA is getting research that only benefits about 10 percent of the clients. The remaining clients are paying the same fees, but they are not getting the same benefit. If BIA were to inform all of its clients of the arrangement, it might not be a violation, but the vignette says that information has not been disclosed.

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