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Bill Fence, CFA, supervises a group of research analysts, none of whom have earned the CFA designation or are CFA candidates. On several occasions he has attempted to get his firm to adopt a compliance system to ensure that applicable laws and regulations are followed. However, the firm's principals have never adopted his recommendations. Fence should most appropriately:

A) decline in writing to accept supervisory responsibility until reasonable compliance procedures are adopted.

B) resign from the firm, because no other alternative will keep him in compliance with the Code and Standards.

C) take no further action, because by encouraging his firm to adopt a compliance system he has fulfilled his obligations under the Code and Standards.

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According to Standard IV(C), Responsibilities of Supervisors, if the member cannot discharge supervisory responsibilities because of a poor or nonexistent compliance system, the member should decline in writing to accept supervisory responsibility until the firm adopts an adequate system. The standard does not require Fence to resign.

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Martin Tripp, CFA, is vice-president of the equity department at Walker Financial, a large money management firm. Of the twenty analysts in his department for whom he has supervisory responsibility, eight are subject to CFA Institute Standards of Professional Conduct. Tripp believes that he cannot personally evaluate the conduct of the twenty analysts on a continuing basis. Therefore, he plans to delegate some of his supervisory duties to Sarah Green, who is subject to the Standards, and some to Bob Brown, who is not subject to the Standards. According to CFA Institute Standards of Professional Conduct, which of the following statements about Tripp's ability to delegate supervisory duties is most correct?

A) Tripp can delegate some or all of his supervisory duties to Brown, even though Brown is not subject to the Standards.

B) Tripp cannot delegate any of his supervisory duties to either Green or Brown.

C) Tripp can delegate some or all of his supervisory duties only to Green because she is subject to the Standards.

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Standard IV(C), Responsibilities of Supervisors, permits Tripp to delegate supervisory duties to Green, Brown, or both, but such delegation does not relieve Tripp of his supervisory responsibility.

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Which of the following is least likely a recommended procedure for supervisors and compliance officers to comply with Standard IV(C), Responsibilities of Supervisors?

A) Hold hearings when violations have occurred to determine the severity of the violations.

B) Disseminate the firm's compliance procedures to employees.

C) Incorporate a professional conduct evaluation into the employee's performance review.

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While a supervisor should respond promptly and investigate violations, there is no obligation to hold hearings when violations have occurred.

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Jess Green, CFA is the research director for Castle Investment, Inc., and has supervisory responsibility over eight analysts, including three CFA charterholders. Castle has a compliance program in place. According to CFA Institute Standards of Professional Conduct, which of the following is NOT an action that Green should take to adhere to the compliance procedures involving responsibilities of supervisors? Green should:

A) issue periodic reminders of the procedures to all analysts under his supervision.

B) disseminate the contents of the compliance program to the eight analysts.

C) incorporate a professional conduct evaluation as part of the performance review only for the three CFA charterholders.

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Green should incorporate a professional conduct evaluation as part of his review of all eight analysts under his supervision, not just the three CFA charterholders.

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Edwin McNeill, CFA, is a senior trader for Grey Securities. In his monthly review of his team’s activity, McNeill notices a series of suspicious trades by one of the traders. McNeill consults his manager, who agrees that these trades are a potential violation. McNeill informs the trader that her duties will be restricted while these trades are being investigated and refers the matter to Grey’s compliance officer for further action. McNeill has:

A) violated Standard IV(C) – Responsibilities of Supervisors by restricting the trader’s duties before the investigation is completed.

B) violated Standard IV(C) – Responsibilities of Supervisors by failing to prevent a potential violation.

C) not violated the Standards.

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By reviewing the employee’s conduct, restricting the employee’s activities while investigating a potential violation, and referring the matter to his manager and compliance officer, McNeill acted properly according to Standard IV(C) – Responsibilities of Supervisors. Wrongdoing by a subordinate does not mean the manager has violated Standard IV(C) as long as adequate procedures to detect and prevent violations are in place and the manager enforces them.

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Dixie Miller, CAIA, and Level II CFA candidate, heads the research department of a large brokerage firm. The firm has many analysts, some of whom are subjected to the CFA Institute Code of Ethics and Standards of Professional Conduct. If Miller delegates some of her supervisory duties, which statement best describes her responsibilities under the CFA Institute Code and Standards?

A) Miller retains supervisory responsibilities for those duties delegated to her subordinates.

B) CFA Institute Standards prevent Miller from delegating supervisory duties to subordinates.

C) Miller's supervisory responsibilities do not apply to those subordinates who are not subjected to the CFA Institute Code and Standards.

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Even though members may delegate supervisory duties, such delegation does not relieve members of the supervisory responsibility.

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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.

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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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Karen Dalby, CFA, is a rising star at a major investment bank and has an extremely demanding schedule. To avoid "burning out" new hires, the bank has instituted a mandatory vacation policy which requires employees to take at least 5 days of vacation per year. At the end of the year, Dalby has taken no vacation, but is scheduled to travel to Fiji to take the mandatory 5 days. The bank’s most important client is suddenly targeted in a hostile takeover and asks specifically for Dalby to join the takeover defense team. Her supervisor, Hank Lone, CFA, asks Dalby to cancel her vacation and she complies. Lone is most likely:

A) not in violation of the Code and Standards.

B) in violation of Standard IV(A) "Loyalty."

C) in violation of Standard IV(C) "Responsibilities of Supervisors."

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Lone has a responsibility to equally enforce all firm policies to demonstrate that all rules are equally important.

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Susan Tigra, CFA, is a portfolio co-manager for the Sandia Energy pension fund. She has been contacted by Ted Garnet, a former classmate. Garnet has started his own investment management firm and would like Sandia Energy to move a portion of its assets to be managed by his firm. Tigra moves 5% of the pension fund to Garnet’s firm to help him build his assets under management. Kurt Show, CFA, is Tigra’s supervisor. Show notes the move, but does not investigate. Show is most likely:

A) not in violation of the Code and Standards.

B) in violation of Standard IV(C) "Responsibilities of Supervisors."

C) in violation of Standard V(A) "Diligence and Reasonable Basis."

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Show should review important changes to the portfolio for compliance with firm policies and procedures. The decision to work with Garnet seems arbitrary, and may not be necessary or prudent.

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Don Wilson and Nadine Chavis, both CFA charterholders, are investment advisors at Uptown Securities. Wilson recommends that one of his clients buy Alpha Company based on research conducted by Uptown. Chavis recommends that one of her clients sell Alpha Company based on research conducted by another brokerage firm for general distribution. Both recommendations are consistent with each client's investment objectives and within the context of their entire portfolios. Neither Wilson nor Chavis has reason to suspect that any information contained in the research reports from these two sources is inaccurate or inadequately supported. According to Standard V(A) Diligence and Reasonable Basis, do Wilson and Chavis have a reasonable basis for making their investment recommendations?

A) Only one of these advisors has a reasonable basis for his or her recommendation.

B) Neither of these advisors has a reasonable basis for their recommendations.

C) Both of these advisors have a reasonable basis for their recommendations.

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Wilson and Chavis have a reasonable and adequate basis if they recommend an investment transaction based on sound research prepared by their firm or an independent third party.