CFA Level II ExamEthical and Professional StandardsMedium

Emily Carter, CFA, a research analyst at 'Global Equities,' is preparing a research report on 'Tech Innovations Inc.' She has diligently researched the company, spoken with management, and analyzed its financials. Her report concludes with a 'Buy' recommendation. Just before publication, she learns that her firm's investment banking division is about to launch a major secondary offering for Tech Innovations Inc. Emily does not own any shares of Tech Innovations Inc. What is Emily's most appropriate action under the CFA Institute Standards of Professional Conduct regarding this conflict of interest?

  1. AProceed with publishing the 'Buy' recommendation, as her research is objective and independent.
  2. BDisclose the potential conflict of interest prominently in her research report and to the firm's compliance department.
  3. CChange her recommendation to 'Hold' or 'Sell' to avoid any appearance of conflict, regardless of her research findings.
  4. DDelay the publication of her research report until the secondary offering is completed.
Show answer & explanation

Correct answer: B. Disclose the potential conflict of interest prominently in her research report and to the firm's compliance department.

Emily has a conflict of interest due to her firm's investment banking activities with the company she is covering. Standard VI(A) Disclosure of Conflicts requires her to disclose this conflict prominently. Maintaining objectivity in her research is paramount (Standard I(B) Independence and Objectivity), but disclosure is the primary way to manage the conflict.

Why the other options are wrong

  • A. While her research may be objective, failing to disclose the conflict of interest violates Standard VI(A).
  • C. Changing her recommendation solely to avoid the appearance of conflict would compromise her independence and objectivity (Standard I(B)). Her recommendation should be based on her research.
  • D. Delaying publication might not be in the best interest of her clients/readers who need timely information, and it doesn't resolve the underlying conflict of interest, only postpones its disclosure.

Disclosure of Conflicts (VI(A))

Members and Candidates must make full and fair disclosure of all matters that could reasonably be expected to impair their independence and objectivity or interfere with their duties to clients, prospective clients, or their employer.

  • Disclose all actual and potential conflicts of interest.
  • Disclosure must be prominent and timely.
  • Applies to personal, firm, and client conflicts.

Memory trick: Firm's Conflicted? Disclose, Don't Disguise.

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