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"morality" exercise:Performance Presentation,
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Questions 1:
Abe Seneca, CFA, supervises a team of analysts who create index funds for institutional investors. When Seneca makes sales demonstrations without his colleagues to potential clients simulating the fund’s performance, the scenarios he prepares show outcomes based on assumptions reflecting upside bias and positive risk assessments. Gail Tremblay, CFA, an analyst in Seneca’s group, observes that the actual performance of these index funds is less than indicated in the scenario outcomes shown in the sales meetings. Seneca least likely violated which of the following CFA Institute Standards of Professional Conduct?
A 、Loyalty
B、 Performance Presentation
C、 Responsibilities of Supervisors
Questions 2:
Eileen Fisher, CFA, has been a supervisory analyst at SL Advisors for the past ten years. Recently, one of her analysts was found to be in violation of the CFA Institute Standards of Professional Conduct. Fisher has placed limits on the analyst’s activities and is now monitoring all of his investment activities. Although SL did not have any compliance procedures up to this point, to avoid future violations, Fischer has put in place procedures exceeding industry standards. Did Fisher most likely violate any CFA Institute Standards of Professional Conduct?
A、 Yes.
B 、No, because she has taken steps to ensure the violations will not be repeated by the analyst.
C、No, because she is taking steps to implement compliance procedures that are more than adequate.
View answer resolution
【Answer to question 1】C
【analysis】
C is correct because Standard IV(C)–Responsibilities of Supervisors has not been violated as Seneca is not responsible for the supervision of any employees when he makes sales demonstrations to clients because he prepared the material himself. Seneca violated Standard IV(A)–Loyalty by misleading potential investors on the performance they might achieve with the index funds, thereby causing reputational risk to his employer. Seneca has also violated Standard III(D)–Performance Presentation because the sales demonstrations he conducts do not provide a fair and accurate representation of performance clients are likely to experience.
A is incorrect because Seneca understates risks and only includes positive assumptions in his sales presentations in order to achieve higher simulated performance. This is a violation of Standard IV(A)–Loyalty because he is causing reputational risk to his employer by misleading potential investors on the performance they might achieve with the index funds. Standard IV(A) requires members and candidates to protect the interests of their firm by refraining from any conduct that would injure the firm.
B is incorrect because Seneca has violated Standard III(D)–Performance Presentation because the sales demonstrations he conducts do not provide a fair and accurate representation of performance clients are likely to experience.
【Answer to question 2】A
【analysis】
A is correct because under standard IV(C) a member should exercise reasonable supervision by establishing and implementing compliance procedures prior to the possibility of any violation occurring, which has not been done in this case.
B is a correct action but does not address the standard violation. These actions are intended to restrict activities after the violation and do not relate to investigating why or how the violation occurred, which would be necessary to establish and implement adequate compliance procedures.
C is a correct action but the steps were taken after the fact and procedures should have been in place previously.
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