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Reading 2-III: Standards of Professional Conduct & Gui

6In securing the shares for all accounts under her management, Linda Kammel of Northwest Futures purchased three blocks of shares at three different prices. She then allocated these shares by placing shares from the first block in accounts with surnames beginning with A-G. The second was allocated over accounts H-P, and the third over Q-Z. This action is:

A)   not permissible under the Code and Standards.

B)   consistent with her responsibilities under the Code and Standards.

C)   permissible so long as the commissions per share are the same across all accounts.

D)   permissible only if the clients are informed of the allocation procedure.

7Which of the following statements regarding allocating trades is TRUE? It is permissible under the Standards to allocate trades:

A)   on a pro-rata basis over all suitable accounts.

B)   based upon compensation arrangements.

C)   based upon client relationships with the firm.

D)   based upon any method the firm deems suitable so long as the allocation procedure has been disclosed to all clients.

8Concerning Standard III(B), Fair Dealing, which of the following actions is NOT a valid procedure for compliance with the Standard?

A)   Communicate investment recommendations simultaneously within the firm and to customers, where possible.

B)   Communicate investment recommendations to all customers including those accounts for which the securities are not eligible for purchase.

C)   Limit the number of people that are involved and are privy to the fact that an investment recommendation is going to be disseminated.

D)   Establish a systematic method for reviewing the fairness of investment actions taken.

9Rey Sanchez, CFA, covers the specialty chemical industry for Rock Advisory Associates. Until today he has had a buy recommendation on ChemStar, and many of the firm’s customers have purchased shares based upon his recommendation. The firm’s client accounts are divided into two fundamental categories: trading and buy-and-hold accounts. The firm holds discretionary trading authority over the trading accounts, but not the buy-and-hold accounts. Sanchez has recently come to believe that the fundamentals are changing for the worse at ChemStar, and is preparing a sell recommendation. He calls a meeting of the firm’s portfolio managers with accounts holding ChemStar and tells them of the pending release of the sell recommendation. On this basis, the portfolio managers sell all positions in the discretionary accounts but not in the buy-and-hold accounts. Sanchez completes and mails the report to all clients two days later, and, shortly thereafter, many of the buy-and-hold accounts sell their ChemStar positions. With regard to these actions, Sanchez is:

A)   in violation of the Standard on Fair Dealing; the portfolio managers are not in violation of the Standard on Fair Dealing.

B)   not in violation of the Standard on Fair Dealing; the portfolio managers are in violation of the Standard on Fair Dealing.

C)   in violation of the Standard on Fair Dealing; the portfolio managers are in violation of the Standard on Fair Dealing.

D)   not in violation of the Standard on Fair Dealing; the portfolio managers are not in violation of the Standard on Fair Dealing.

10Which of the following statements about the limitations that the Fair Dealing standard imposes is TRUE?

A)   Clients should not be discriminated against when disseminating investment recommendations.

B)   Referral fees may be disclosed after proceeding with an agreement for service.

C)   The selection of a broker should be based solely on the principles of best price and results achieved.

D)   Before trading on her own portfolio, a CFA charterholder must wait for employer and client deals to be executed.

答案和详解如下:

6In securing the shares for all accounts under her management, Linda Kammel of Northwest Futures purchased three blocks of shares at three different prices. She then allocated these shares by placing shares from the first block in accounts with surnames beginning with A-G. The second was allocated over accounts H-P, and the third over Q-Z. This action is:

A)   not permissible under the Code and Standards.

B)   consistent with her responsibilities under the Code and Standards.

C)   permissible so long as the commissions per share are the same across all accounts.

D)   permissible only if the clients are informed of the allocation procedure.

The correct answer was A)

Standard III(B) requires a member to deal fairly with all clients when taking investment actions. Since she knew at the outset that she was going to place shares in all accounts, regardless of the first letter of the surname, all accounts must participate on a pro-rata basis in each block in order to conform to the Standard. Her actions constitute a violation of the Standard concerning fair dealing.

7Which of the following statements regarding allocating trades is TRUE? It is permissible under the Standards to allocate trades:

A)   on a pro-rata basis over all suitable accounts.

B)   based upon compensation arrangements.

C)   based upon client relationships with the firm.

D)   based upon any method the firm deems suitable so long as the allocation procedure has been disclosed to all clients.

The correct answer was A)

It is permissible to allocate trades on a pro-rata basis over all suitable accounts. It is not permissible to base allocations upon compensation arrangements or client relationships. Any method is not necessarily suitable, and disclosure does not absolve the member from ensuring that the allocation is necessarily fair.

8Concerning Standard III(B), Fair Dealing, which of the following actions is NOT a valid procedure for compliance with the Standard?

A)   Communicate investment recommendations simultaneously within the firm and to customers, where possible.

B)   Communicate investment recommendations to all customers including those accounts for which the securities are not eligible for purchase.

C)   Limit the number of people that are involved and are privy to the fact that an investment recommendation is going to be disseminated.

D)   Establish a systematic method for reviewing the fairness of investment actions taken.

The correct answer was B)    

To ensure compliance with the Standard, members should seek to communicate investment recommendations to all clients who have indicated an interest and also those for whom the securities are suitable. There is no need to communicate recommendations to clients for whom the securities are deemed unsuitable. The standard does not prohibit a firm from offering various levels of service.

9Rey Sanchez, CFA, covers the specialty chemical industry for Rock Advisory Associates. Until today he has had a buy recommendation on ChemStar, and many of the firm’s customers have purchased shares based upon his recommendation. The firm’s client accounts are divided into two fundamental categories: trading and buy-and-hold accounts. The firm holds discretionary trading authority over the trading accounts, but not the buy-and-hold accounts. Sanchez has recently come to believe that the fundamentals are changing for the worse at ChemStar, and is preparing a sell recommendation. He calls a meeting of the firm’s portfolio managers with accounts holding ChemStar and tells them of the pending release of the sell recommendation. On this basis, the portfolio managers sell all positions in the discretionary accounts but not in the buy-and-hold accounts. Sanchez completes and mails the report to all clients two days later, and, shortly thereafter, many of the buy-and-hold accounts sell their ChemStar positions. With regard to these actions, Sanchez is:

A)   in violation of the Standard on Fair Dealing; the portfolio managers are not in violation of the Standard on Fair Dealing.

B)   not in violation of the Standard on Fair Dealing; the portfolio managers are in violation of the Standard on Fair Dealing.

C)   in violation of the Standard on Fair Dealing; the portfolio managers are in violation of the Standard on Fair Dealing.

D)   not in violation of the Standard on Fair Dealing; the portfolio managers are not in violation of the Standard on Fair Dealing.

The correct answer was C)    

Sanchez is in violation of the Standard III(B), Fair Dealing, since he has disseminated his recommendation preferentially to the portfolio managers in advance of making the report available to all clients who hold shares of ChemStar. The portfolio managers are in violation of the Standard since they are effectively giving preferential treatment to the trading accounts over the buy-and-hold accounts in the placement of orders based upon the change in recommendation.

10Which of the following statements about the limitations that the Fair Dealing standard imposes is TRUE?

A)   Clients should not be discriminated against when disseminating investment recommendations.

B)   Referral fees may be disclosed after proceeding with an agreement for service.

C)   The selection of a broker should be based solely on the principles of best price and results achieved.

D)   Before trading on her own portfolio, a CFA charterholder must wait for employer and client deals to be executed.

The correct answer was A)    

The dissemination of information and recommendations to clients must be handled fairly.

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