📖 Standard VI(A)-(C) 模拟测试（7题）+ 讲评

Mock Test

Suggested time: 12 minutes

Q1. A portfolio manager personally holds 2,000 shares of XYZ Company (2% of total assets); the fund also holds this stock. The manager writes an internal report recommending an increased position in XYZ but does not disclose the personal holding in the report. This violates:

A) Only VI(A)
B) Only VI(B)
C) VI(A), and potentially I(B)
D) No violation — 2% is not material

Q2. An analyst is invited to a company's "Investor Day"; the company pays for flights and hotel (value approximately $1,500). The analyst accepts and discloses this in a subsequent research report. Is this compliant?

A) Non-compliant — no hospitality may ever be accepted
B) Compliant — accepted but disclosed
C) Gray area — $1,500 may exceed reasonable limits; best practice is to decline
D) Compliant — as long as the amount does not exceed $2,000

Q3. Under the transaction priority rule, the correct ranking is:

A) Personal account → Employer proprietary → Client discretionary
B) Client discretionary → Employer proprietary → Personal account
C) Employer proprietary → Client discretionary → Personal account
D) All accounts treated equally

Q4. Regarding VI(C) referral fee disclosure, which of the following is correct?

A) Disclosure is required only when a client asks
B) Must be disclosed to the client and employer before or at the time of the referral
C) Non-cash referral fees need not be disclosed
D) No disclosure is needed if the amount is below $500

Q5. A fund manager finds an IPO extremely attractive. After allocation, the manager gives 70% to the highest-fee-paying clients and 30% to the rest, reasoning that "high risk, high reward suits high-end clients." This:

A) Is compliant — high-end clients have stronger risk tolerance
B) Violates VI(B) — IPO allocation cannot be ranked by fee level; must follow III(B) fair dealing
C) Is compliant — a reasonable use of discretion
D) Violates only III(C) suitability

Q6. An analyst includes a conflict-of-interest disclosure in a research report, but places it in a footnote at the end of the report, using small font and legal jargon. This:

A) Is compliant — having disclosure satisfies the requirement
B) Is a violation — not prominent (insufficiently prominent), not in plain language
C) Is compliant — as long as the content is complete
D) Is a violation — but only of I(B), not VI(A)

Q7. Comprehensive: Fund Manager A manages two funds. A receives "soft dollars" (research services) from Broker B, and in exchange, A allocates more trading volume to B. A does not disclose this arrangement to clients. A also uses advance knowledge of block trades to trade for a personal account before client trades. Which violations does A's conduct involve?

A) VI(A) + VI(B)
B) VI(A) + VI(B) + VI(C)
C) VI(A) + VI(B) + III(A) + I(B)
D) VI(A) + VI(B) + VI(C) + III(A) + II(A) (if the information is nonpublic)

Answer Key & Explanations

Q1 Answer: C — VI(A), and potentially I(B)

Explanation: - Personal holding is a classic conflict of interest → undisclosed = VI(A) violation - If the holding affected the objectivity of the recommendation → I(B) independence compromised - Whether 2% is "material" is not the core issue — the CFA Code does not provide a holding-percentage exemption; the key is whether the client would consider it important

Q2 Answer: C — Gray area; $1,500 may exceed reasonable limits

Explanation: - $1,500 in hospitality likely exceeds acceptable limits under most compliance policies - Although disclosed, VI(A)'s best practice is to avoid accepting benefits that may compromise independence - The safer approach: pay out of pocket or decline

Q3 Answer: B — Client discretionary → Employer proprietary → Personal account

Explanation: - The explicit VI(B) ranking: Client > Company > Character - Discretionary clients have the highest priority (heaviest fiduciary duty)

Q4 Answer: B — Must be disclosed to client and employer before or at the time of the referral

Explanation: - A is wrong: cannot wait for clients to ask - C is wrong: non-cash referral fees must also be disclosed - D is wrong: there is no monetary exemption threshold - "Before or at the time" is the timing requirement; "client + employer" is the recipient requirement

Q5 Answer: B — Violates VI(B); allocation cannot be ranked by fee level

Explanation: - IPO allocation is a core concern area for VI(B) + III(B) - Allocating by fee level = unfair to lower-fee clients - "High risk, high reward" is not a justification for fee-based allocation

Q6 Answer: B — Not prominent enough and not plain language

Explanation: - VI(A) explicitly requires: prominent + plain language - Small-font footnotes + legal jargon = both requirements violated - "Having disclosure" ≠ "effective disclosure"

Q7 Answer: D — Nearly all violations (depending on the nature of the information)

Explanation — breakdown: - Soft dollar arrangement undisclosed → VI(A) conflict not disclosed + III(A) loyalty (soft dollars must benefit the client) - Allocating more trading volume for soft dollars → potentially III(A) (soft dollars not directly benefiting the client) - Trading ahead for personal account → VI(B) transaction priority - If using nonpublic block trade information → II(A) insider trading - Referral fee nature of soft dollars if undisclosed → VI(C)

This is a "grand slam" question type. In the exam, you must be able to identify every violation one by one.

Performance Assessment

End of Standard VI. Next L087: Module 2 — Quantitative Methods