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Reading 2-VI: Standards of Professional Conduct & Guida

1A firm produces regular proprietary research reports on various companies. According to Standard VI(B), Priority of Transactions, which of the following would be an “access person?”

A)   A person working in the mail room.

B)   An independent auditor with access to material, non-public information on a company being analyzed.

C)   A supervisory analyst who reviews all research reports prior to dissemination.

D)   An agent from a government agency that reviews the compliance procedures of the analyzing firm.

2An unpaid intern at an investment firm has the task of photocopying unannounced investment recommendations after all regular employees have left for the day. With respect to Standard VI(B), Priority of Transactions, the firm:

A)   is acting appropriately by having an unpaid intern do the job.

B)   is acting appropriately by having the intern perform the task after all employees have left.

C)   cannot be in violation because Standard VI(B) does not address this issue.

D)   is probably violating the Standard.

3An analyst likes to trade options in her own account. She does not deem any of her client accounts suitable for option trading. When she finds a favorable options position, in accordance to Standard VI(B), Priority of Transactions, she should:

A)   act on it on her own behalf as she sees fit.

B)   first tell her clients about it before acting herself.

C)   act on it immediately on behalf of her clients then act on her behalf.

D)   refrain from acting until she notifies her supervisor.

.

4An analyst routinely has the opportunity to offer his clients the opportunity to purchase “hot new issues.” He tells his clients that he will distribute each issue equally among those interested, with himself included in the distribution. The clients do not object to this. With respect to Standard VI(B), Priority of Transactions, this:

A)   cannot be a violation because the clients know of the practice and agree.

B)   may be a violation despite the clients' approval.

C)   may be a violation because it is impossible to distribute hot new issues equally.

D)   may be a violation because clients should not be offered "hot" securities.

5Standard VI(B), Priority of Transactions, applies to transactions an analyst takes on behalf of:

A)   all of these.

B)   his employer.

C)   his clients.

D)   personal accounts.

答案和详解如下:

1A firm produces regular proprietary research reports on various companies. According to Standard VI(B), Priority of Transactions, which of the following would be an “access person?”

A)   A person working in the mail room.

B)   An independent auditor with access to material, non-public information on a company being analyzed.

C)   A supervisory analyst who reviews all research reports prior to dissemination.

D)   An agent from a government agency that reviews the compliance procedures of the analyzing firm.

The correct answer was C)

Persons with access to information during the normal preparation of research recommendations are subject to Standard VI(B). A compliance officer should not have access to such materials. An independent auditor is not involved in the normal preparation of research recommendations.

2An unpaid intern at an investment firm has the task of photocopying unannounced investment recommendations after all regular employees have left for the day. With respect to Standard VI(B), Priority of Transactions, the firm:

A)   is acting appropriately by having an unpaid intern do the job.

B)   is acting appropriately by having the intern perform the task after all employees have left.

C)   cannot be in violation because Standard VI(B) does not address this issue.

D)   is probably violating the Standard.

The correct answer was D)

Among other things, Standard VI(B) covers how the firm keeps unannounced information confidential. At a minimum, the intern should be supervised by someone familiar with the Code and Standards. The firm needs to have adequate procedures for preventing the dissemination of information before it is released to the public. One method of doing so is to limit the number of access persons privy to confidential information. An intern should not be an access person.

3An analyst likes to trade options in her own account. She does not deem any of her client accounts suitable for option trading. When she finds a favorable options position, in accordance to Standard VI(B), Priority of Transactions, she should:

A)   act on it on her own behalf as she sees fit.

B)   first tell her clients about it before acting herself.

C)   act on it immediately on behalf of her clients then act on her behalf.

D)   refrain from acting until she notifies her supervisor.

The correct answer was A)

This is not a violation of Standard VI(B), Priority of Transactions, because the investment is not suitable for her clients. If the analyst believes that none of her clients should trade options, she is not obligated to advise them in this instance.

4An analyst routinely has the opportunity to offer his clients the opportunity to purchase “hot new issues.” He tells his clients that he will distribute each issue equally among those interested, with himself included in the distribution. The clients do not object to this. With respect to Standard VI(B), Priority of Transactions, this:

A)   cannot be a violation because the clients know of the practice and agree.

B)   may be a violation despite the clients' approval.

C)   may be a violation because it is impossible to distribute hot new issues equally.

D)   may be a violation because clients should not be offered "hot" securities.

The correct answer was B)

Just because the clients know of a practice does not make it right. The analyst must put the clients first. It is a violation for the analyst to participate in a “hot new issue” which can lower the allocation to any given client below what that client would prefer. This is tantamount to putting the analyst’s interests ahead of the clients’ interests.

5Standard VI(B), Priority of Transactions, applies to transactions an analyst takes on behalf of:

A)   all of these.

B)   his employer.

C)   his clients.

D)   personal accounts.

The correct answer was A)

Standard VI(B) addresses the treatment of all these accounts. The accounts of clients and employers have priority over personal accounts.

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