- Must know all the laws o CFA Code of Conduct and other Code and Standards o Applicable Law that governs your conduct such as federal regulations o Abide by the stricter standard - Must not knowingly do an illegal or unethical act o Inaction with association => construed as participation - If you recognize that there’s an unethical behavior o Try to stop it o If that fails, go talk to compliance o If none of this works, dissociate from the firm Dissociate – Don’t participate with the firm Don’t write your name on the research reports Don’t take new clients - To maintain knowledge of law o Stay informed about the laws o Review firm’s procedures regarding certain situations o Maintain current files of applicable standards IB. Independence and Objectivity - Maintaining reasonable care and judgement to maintain independence and objectivity o Don’t accept gifts that would compromise your integrity - Create a guideline to make sure there are no grey lines for employees - Compensation should not be linked to other revenue generating office such as corporate finance team IC. Misrepresentation - Must not knowingly misrepresent investment analysis, recommendations, actions or other professional activities o Be honest about firm’s performance and investment’s risks/unpredictability o Don’t plagiarize and perform due diligence on third party’s material o Disclose external managers IC. Misconduct - Engaging in any lies that that compromise one’s professional reputation o Distinguish because your personal reputation does not matter Must be related to a professional matter such as research However, personal issues that has a business element (ex – hiding assets in bankruptcy) will be misconduct Shi H Park 872933676 FIN 3110-1 Standard II: Integrity of Capital Markets
IIA. Material Nonpublic Information
- Material Information – any information a reasonable investor would like to know before investing; this information will affect security’s price o Based on how specific, difference in public information, reliability, and effect - Nonpublic – not disseminated/made available to all market participants o Become public when you distribute information through public channels - Mosaic Theory – if conclusion derived from a combination of public information and nonpublic, nonmaterial information, can use it to make investment recommendations IIB. Market Manipulation - Market Manipulation – Engaging in practices to distort prices or artificially inflate trading volumes to mislead market participants and making profit o Information-Based Manipulation – False rumors to induce others to trade o Transaction-based Manipulation – Misleading market by taking actions to affect security’s price (ex – having dominant position to exploit price) Matched Order – Person place buy and sell order at the same time on low turnover security stocks to induce others to trade Washed Trade – Being the buyer and seller of the same security - Volume manipulation has to be more than 20% of the volume to be have effect