CFA Practice Question

CFA Practice Question

Armina Stump is a junior portfolio manager on the verge of a promotion at Black Stallion, a strongly bullish fund management firm. Armina reports to Brouster Bragg, who has been with the firm for about 8 years. Brouster has been busy over the past 6 months and has not been able to keep up with account reviews but has complete faith in his subordinate managers. Now that it's time for Armina's promotion, he has been going over her transactions in the past 6 months and has discovered that all her trades are going through Blackwell Brokers.

Blackwell is a brokerage firm and is known to give extremely competitive prices and speed on trade executions. Due to the bulk transactions that originate with Armina, Blackwell has been providing research reports and investment tips to Armina which she has found extremely useful. Brouster does not find anything wrong with this, though he has now instructed Armina to file her monthly reports in more detail and in a timely fashion. She explained that due to company work and visits to their Los Angeles office, she had not been able to complete the reports for two months but she would take additional care in the future in this regard. Black Stallion has no official policy about filing of account reports. Given this entire sequence of events, your analysis as a student of CFA Institute ethics code should reveal which of the following?

I. Armina has violated Standard I (A) - Knowledge of the Law by not filing the reports on time.
II. Brouster has violated Standard IV (C) - Responsibilities of Supervisors by failing to enforce proper supervision.
III. Armina has violated Standard III (A) - Loyalty, Prudence, and Care by routing her orders solely through Blackwell.
A. II only
B. II and III only
C. I and II only
Explanation: Since Black Stallion does not require a monthly report from its portfolio managers, Armina has not violated company policy because she is not responsible for monthly reports. However, Brouster still must develop procedures to monitor the actions of his subordinate portfolio managers since he is responsible for their actions.

Indeed, the absence of such a policy at Black Stallion makes it incumbent upon Blackwell to be more diligent about monitoring. By failing to regularly review the accounts for 6 months, Blackwell has left open the possibility of manipulation by his subordinates and is thus in violation of Standard IV (C) - Responsibilities of Supervisors.

Finally, since Armina is getting best price execution from Blackwell, she has not violated any Fiduciary duties. The fact that she receives free research advice due to bulk trades does not automatically imply that her client accounts are being hurt or being made to pay for the services.

Additionally, it should be noted that if Blackwell were to wine and dine Armina as a symbol of appreciation or send her lavish gifts, Armina may be in violation of the Standard I (B) - Independence and Objectivity - because acceptance of such gifts creates an appearance of impropriety even if none is present.

User Contributed Comments 1

User Comment
danlan Good explanation!
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