2023 CFA L2 Book 4 PM Ethics
2023 CFA L2 Book 4 PM Ethics
2023 CFA L2 Book 4 PM Ethics
JuiceNotes 2023
INDEX
Portfolio Management
Name of Reading
38 Exchange Traded Funds: Mechanics & Applications 5
39 Using Multifactor Models 10
40 Measuring And Managing Market Risk 13
41 Backtestibg and Simulation 17
42 Economics And Investment Markets 19
43 Analysis Of Active Portfolio Management 22
44 Trading Costs and Electronic Markets 25
Ethics
Name of Reading
45 Ethics and Trust in Investment Profession 39
46 Code of Ethics 40
47 Guidance of Standards I-VII 41
48 Required Vs Recommended 64
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Portfolio Managements
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Ÿ Low cost
Ÿ Exchange access
Ÿ Holdings transparency
ª Trading & settlement system are fragmented which may lead to wider spreads & trading
costs.
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Driver of ETF bid-ask spreads are market structure and liquidity of underlying
securities held
Ÿ +Creation/redemption fees
and other direct trading
costs
Ÿ Amount of ongoing order
flow (measured by daily Ÿ +Bid-ask spreads
share volume) securities held in the ETF
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LOS e Describe sources of ETF premiums & discounts to NAV
Ÿ End-of-day ETF premium or discount (%) =(ETF price - NAV per share) / NAV per share
Ÿ Intradary ETF premium or discount (%) = (ETF price - iNAV per share) / iNAV per share
Ÿ Timing differences
Ÿ Stale pricing
Ÿ Trading costs : Bid ask spreads & commissions : incurred only at purchase or sale and return impact
diminishes over longer holding periods
Ÿ Other implicit trading costs-portfolio turnover costs: reflected in fund returns and incurred when
portfolio manager buys/sell securities to execute investment strategy
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ETF Strategies
Ÿ Protfolio efficiency
Ÿ International regions or
countries with/without
currency exposure
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Ÿ Factor (smart beta) ETFs: Factor ETFs are benchmarked to an index with predefined rules for
screening and/or weighting constituent securities
Ÿ Risk Management : Some smart beta ETFs focus on achieving higher or lower risk relative to their
asset class benchmark
Ÿ Alternatively, weighted ETFs :ETFs which use weighting schemes other than market capitalization
for constituent stocks can be used to implement investment views.
Ÿ Discretionary active ETFs : Largest actively managed ETFs are in fixed income where passive
management is less prominent compared to equities.
Ÿ Liquid alternative ETFs : Attempt to deliver absolute return performance and/or risk diversification
of stock and bond holdings
Ÿ Dynamic asset allocation and multi-asset strategies : Dynamic asset allocation strategies may
allocate holdings on the basis of their risk contribution while others are return focused, but all
strategies involve adjustments back to target weights. These strategies are either implemented in-
house or by hiring external managers offering multi asset strategies.
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Assumptions
ª Returns are generated using a factor model
APT equation:
Rp = RFR + β1 × Factor risk premium1 + β2 × Factor risk premium2 + .... + βn × Factor risk premiumn
Unlike CAPM, APT does not require one of the factors to be ERP
A 2 20%
B 1 12%
C 1.5 14%
W1 × 2 + W2 × 1 = 1.5 2 1
W1 = 50%, W2 = 50%
1.5
0.5 × 20% + 0.5 × 12% = 16%
A 0.9 17%
B 1.7 25%
Active Active
Factor Security
factor specific
return selection
risk risk
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VaR
Lookback period: Time period used to estimate expected return and SD for each risk factor
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LOS d Advantages and limitations of VaR
Advantages Limitations
Used to estimate the change in portfolio value Used to estimate the change in portfolio value
for a given change in risk factor for changes in multiple risk factor
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LOS h Use of sensitivity risk measures and scenario risk measures
Sensitivity risk measures and scenario risk measures allow a
risk manager to hedge appropriately
Pension fund
Banks Life insurers
managers
Asset
P&C insurers
managers
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LOS k Constraints used in managing market risks
Risk budgeting: Allocation of total risk to different activities,
strategies or asset classes
Scenario limits: Limits on estimated loss for a given scenario
Stop loss limits: Require reduction in size of a portfolio, if losses
exceed a specified amount in a specified period
Position limits: Limit on allocations to securities within an asset class
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LOS b&c Describe steps and procedures in back testing an investment strategy
It is a Techniques for exploring how a target variable is affected by changes in input variables
1 − P0
Real rate:
P0
Higher the utility for current consumption, higher the real rate
If investors expect higher incomes in the future, their expected marginal utility
of future consumption is decreased relative to current consumption
If expected returns are high or there is high uncertainty about future income,
there will be an increase in savings
Investors experience a larger loss of utility for a loss in wealth as compared with
a gain in utility for gain in wealth. This is called as risk-aversion
Risk aversion can be explained by the covariance of investor’s inter-temporal
marginal rate of substitution and expected returns on savings
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LOS d Effects of business cycle phases
Interest rate for short-term securities: Real rate + Expected inflation
Interest rate for long-term securities: Real rate + Expected inflation + Risk premiuminflation
Investor expectation about higher future GDP growth leads to +ve slope of yield curve
Policy rates tend to be lower in recessionary environment and higher in expansionary environment
Yield curve is +ve because normal term spread (YTM on long-term bond – YTM on short-term bond) is +ve
Credit spreads tend to rise during the times of economic weakness and
fall during expansions
Discount rate = Real rate + Expected inflation + Risk premiuminflation + Risk premiumcredit risk + ERP
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LOS j Cyclical effects on valuation multiples
Multiples rise during expansion and fall during contraction (factoring in expected growth)
Price multiples are positively correlated with expected earnings growth rates and
negatively correlated with required returns
An investors would generate superior returns if he could rotate out of the under-performing
sector and into the better performing sector right before the change in performance
Understanding the relationship b/w equity market performance of different sectors and the
business cycle would help analysts enhance their sector rotation strategies
Ex post risk premiums on equity = Average return on a sector − Short term RFR
ª Discount rate:
Real rate + Expected inflation + Risk premiuminflation + Risk premiumcredit risk + ERP + Risk premiumilliquidity
ª Rental income is relatively stable across business cycles, but property values tend to be very cyclical
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Active weights: Weight of security in portfolio (Wp) − Weight of security in benchmark (WB)
Overweighted securities: +ve active weights
Underweighted securities: −ve active weights
LOS b
Information ratio (IR) Sharpe ratio (SR)
Active return
Active risk Rp − RFR
σp
Generally;
Ex-ante ratio is +ve, and Unaffected by the
Ex-post ratio is −ve addition of cash or use of
leverage in the portfolio
Affected by the addition
of cash or use of leverage Sharpe ratio of a
in the portfolio portfolio with optimal
level of active risk:
Unaffected by the
aggressiveness of the SR2P = SR2B + IR2, Or
active weights (for SR2P = SR2B + TC2IR2
unconstrained portfolio)
ª Closet index fund: An actively managed fund that closely tracks the benchmark index
ª They have low IR, low active risk and Sharpe ratio that is similar to the benchmark index
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Forecasted
active return
In
C)
fo
(T
rm
Cor (μi/σi, ∆Wiσi) Cor (RAi/σi, μi/σi)
at
en
io
(Correlation b/w (Correlation b/w
ci
n
ffi
forecasted returns and realized active returns
co
oe
effi
risk adjusted weights) and forecasted returns)
c
er
ci
sf
en
an
t
(I
Tr
C)
Active Realized
weights active return
Value added
E(RA) = IR × σA
IR = IC × √BR
Or
IR = TC × IC × √BR
Grinold rule: μ = IC × σi × Si
N
Breadth (BR):
1 + (N − 1) × r
μi σA
Optimal weight for a security (∆Wi): 2
×
σ i
IC × √BR
E(RA/ICR): TC × IC × √BR × σA
TC2 1 − TC2
Portfolio that has the highest IR will also have the highest SR
Therefore, investors will choose the active portfolio manager with the highest IR
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LOS f Strengths and limitations of the fundamental law of active management
Components of fundamental law of active management:
Œ Skill (measured by IC)
Portfolio structuring (measured by TC)
Ž Breadth (measured by number of independent decisions per year)
Aggressiveness (measured by active risk)
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Trading costs include fixed costs and variable costs . Fixed trading costs for buy-and-hold
institutions include costs of:
Ÿ Office space
Explicit costs : Represent direct costs of trading (broker commission costs, transaction costs, stamp
duties, and fees paid to exchanges)
Implicit costs : Indirect costs caused by market impact of trading (price concessions traders make to
complete their trades is known as market impact costs)
Market impact : Effect of trade on transaction prices. Larger orders have greater market impact than
smaller orders
Ÿ Delay costs (also called slippage): Arise from the inability to complete the desired trade immediately
Ÿ Opportunity costs (or unrealized profit/loss): Arise due to a failure to execute a trade promptly
LOS b Calculate and interpret effective spreads and VWAP transaction cost
estimates
Ÿ Dealers provide liquidity to other traders who want to buy/sell securities by trading from their own
account’s inventory.
Ÿ When buying interest > selling interest, dealers raise ask prices to discourage buyers and raise bid
prices to encourage sellers
Ÿ When buying interest < selling interest, dealers lower ask price to encourage buyers and raise bid
price encourage sellers.
Ÿ Dealers are useful in markets which are infrequently traded because they are always willing to take
the other side of the trade and thus makes market more continuous
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Ÿ Inside bid-ask spread will be lower than the individual dealer spreads if the dealer with the highest bid
price is not the dealer with the lowest ask price.
Ÿ Large orders may not fill at a specific bid or ask price and will have price impact as they move down the
limit order book.
Ÿ Implementation shortfall
Effective Spreads
Market spread is a measure of trade execution costs and measures how much traders would lose per
quantity traded if they simultaneously submit buy and sell market orders at respective bid and ask prices.
Ask
Effective Spread : = Trade size xTrade price - Bid+ For Buy Orders
2
Ask
Effective Spread : = Trade size x Bid+ -Trade price For Sell Orders
2
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Effective spread = Market spread if buy orders are submitted at ask prices or sell orders are submitted at
bid prices
Price improvement occurs when buy order fills at a price lower than ask price or sell order fills at a price
higher than offer price and when effective spread < quoted spread.
Effective spread > quoted spread when order fills at a price outside quoted spread and trade execution
prices are worse than quoted prices
Effective spread is a poor estimate of transaction costs for large trades which must be split for
execution over time. This increases market impact
Effective spreads do not measure delay (or slippage) costs.
Delay costs: Arise from the inability to complete desired trade immediately because size > available
market liquidity
Opportunity cost
Costs associated with unfilled orders when there are delays in order execution.
Eg.: Order to buy 10 contracts with a limit price of 99.00 which is good for one day when the market
quote is 99.01 to 99.04. If order doesn’t execute and contract closes at 99.80, the order could have
been filled at 99.04 and opportunity cost per contract is 0.76 (99.80 – 99.04).
VWAP transaction cost estimate = Trade size x Trade VWAP - VWAP Benchmark (For Buy Orders)
VWAP transaction cost estimate = Trade size x VWAP benchmark - Trade VWAP (For Sell Orders)
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Implementation Shortfall
Implementation shortfall method captures implicit and explicit trading costs. The measure includes:
Ÿ Delay costs
Ÿ Opportunity costs
ª Electronic bond order-matching systems exist but they primarily serve dealers and not public
investors.
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Ÿ Electronic trading systems have displaced floor-based trading systems in all instruments for which
order-driven markets are viable. These markets are now organized by most exchanges and electronic
communication networks.
Electronic Bond Order-matching systems exist but they primarily serve dealers and not public
investors.
ª Market fragmentation: Trading the same instrument in multiple venues. Market fragmentation
increases potential for price and liquidity differences across venues.
ª For example, trading of exchange-listed equities is now divided among several exchanges, alternative
trading systems, and numerous dealers.
ª Traders respond to market fragmentation by searching for liquidity across multiple venues and time to
control market impact of large trades.
Liquidity aggregators: Offer global view of market depth (liquidity) for a given instrument regardless of
trading venue
Smart-order routing algorithms send orders to markets that display the best-quoted prices and sizes
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Ÿ Numerous studies prove the decline in transaction costs due to electronic trading due to cost
efficiencies
Ÿ Substantial decline in bid-ask spreads which lowers transaction costs for retail traders and
institutions trading small orders
Ÿ Transaction costs have also decreased for large orders
Ÿ One study shows that the implementation shortfall cost of filling thousands of equity orders for US
stocks has dropped.
Ÿ Buy-side traders
Ÿ Electronic brokers
Proprietary traders are profit-motivated traders and include dealers, arbitrageurs, and various types of
front runners.
Buy-side traders trade to fill orders for investment and risk managers who use the markets to establish
positions for themselves and derive various utilitarian and profit-motivated benefits.
Ÿ Proprietary traders who are not brokers/dealers must send their orders to brokers who forward them to
exchanges who give them sponsored access to fast electronic processing systems
ª Electronic proprietary traders include high-frequency traders (HFT) and low-latency traders.
Both must trade very quickly in response to new information.
Low-Latency Traders
Ÿ Include news traders and parasitic traders
ª News traders feed on electronic news feed
ª Parasitic traders are speculators who base their prediction about future prices on
information they obtain about orders which other traders will fill or intend to fill
Ÿ Need to send or cancel orders very quickly when opening or closing positions.
Ÿ May hold positions for as long as a day or even longer in contrast to HFT
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Ÿ Subscribe to high-speed electronic news feeds which reports news releases made by corporations,
governments, and other sources
Ÿ Analyze received information quickly to determine whether it will move the market and in which
direction
Ÿ Profit by trading against stale orders, which do not reflect the new information
Ÿ Also process news releases, which do not contain quantitative data, using natural language-processing
techniques.
2 Electronic Dealers
Ÿ Place bids and offers with the expectation to profit from round trips at favourable net spreads
Ÿ When prices move against their position, they immediately take liquidity by executing on the
opposite side of their position to reduce exposure
Ÿ Often monitor electronic news feeds and may cancel all orders in a security mentioned in a news
report.
Ÿ Often keep track of scheduled news releases like all dealers and cancel orders before releases to
avoid offering liquidity to traders acting faster than them
Ÿ May try to reduce their position before a scheduled release to avoid holding a risky position
3 Electronic Arbitrageurs
Ÿ Low Latency traders who use artificial intelligence methods to identify when large traders or many
small traders are filling orders on the same side of the market
Ÿ Purchase securities when they perceive an imbalance of buy orders over sell orders will push the
market up and sell securities if the opposite is true
Ÿ Rely on order anticipation strategies to identify predictable patterns in order submission
Ÿ May search for patterns in order submissions, trades, or the relations between trades and other
events
Ÿ In some jurisdictions, dealers and brokers cannot legally front run orders that their clients submit
Ÿ Front runners may look for patterns in executed trades.
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Ÿ Some front runners examine the relation between trades and other events to predict future trades.
Ÿ Attempt to exploit option values of standing orders (limit orders waiting to be filled)
Ÿ Options to trade are valuable because positions can be taken with potentially limited losses.
Ÿ Traders buy (sell) when they can rely on standing buy (sell) orders to get out of their positions.
Ÿ They will stay in a position or contract if prices move in their favour but will exit if prices move
against them.
Ÿ Main risk to quote matchers is that the standing order may be unavailable when needed
6 Buy-Side Traders
Ÿ Large buy-side traders use electronic order management systems (OMSs) to manage their
trading.
Ÿ Traders employ electronic brokers to arrange their trades which support limit or market orders,
advanced orders, trading tactics, and algorithms. Exchange computers may also perform these
functions.
Ÿ OMS: Keeps track of orders that trader’s portfolio manager want to be filled, which orders have
been sent out to be filled, and which fills have been obtained.
Making: Market events offer attractive opportunities to offer liquidity and electronic traders must act
fast enough to acquire priority in trading.
Cancelling: Traders need to quickly cancel undesired orders because market events have increase the
option values of those orders
The low latency of electronic trading systems comes from electronic traders being faster than their
competitors. With increased competition to acquire orders from electronic traders, electronic order-
handling systems have also grown faster.
Latency: The elapsed time between the occurrence of an event and a subsequent action depending on that
event. For example, the event may correspond to a trade at an exchange and the action may correspond to
a cancellation order sent by a trader to another exchange upon learning of the trade.
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LOS h Characteristics and uses of electronic trading systems
Buy-side traders use electronic brokers for advanced orders, trading tactics, and algorithms
provided by their electronic brokers to search for liquidity.
Advanced order types : Advanced orders are limit orders with limit prices which change as market conditions
change.
Example: Pegged limit orders (sometimes called floating limit orders) are those for which the trader would
like to maintain a bid or offer at a specified distance relative to a benchmark.
Trading Tactics: Trading tactic is a plan for executing a simple function which involves the submission of
multiple orders.
Ÿ Instruction to sweep through every market at a given price to find hidden trading opportunities. Depending
on the orders permitted by an exchange, traders have the option of submitting hidden limit orders,
discretionary limit orders, or a midspread order. (A limit order pegged to the midpoint of the quoted bid-ask
spread)
Ÿ To find hidden liquidity in an exchange, an electronic trading system may submit an immediate or cancel
order to the exchange where hidden liquidity is suspected to exist.
Ÿ Another trading tactic involves placing a limit order at some price and hoping it will fill at that price.
Ÿ In electronic markets the most common type of order is the immediate or cancel limit order. Traders use
these orders to discover hidden orders which may stand in the spread between a market’s quoted bid
and ask prices.
Ÿ Electronic traders also attempt to discover hidden orders by pinging the market which involves
submitting a small IOC limit order for a few shares at the price at which they are looking for hidden
orders.
2 Leapfrog
Ÿ Involves the dealer quoting a wide bid-ask spread for the sole purpose of trading at more favourable
prices
3 Flickering Quotes
These represent exposed limit orders that electronic traders submit and then cancel shortly so that
Ÿ
other traders know they are willing to trade at the displayed price
Ÿ Traders can place a hidden limit order at the place where the quote is flickering if they want to trade
Ÿ Taking liquidity on both sides: The costliest and least risky arbitrage trading involves using marketable
orders to fill both legs or positions (buying an undervalued position and selling an overvalued position).
Very fast trading systems must be used to lock in the arbitrage spread before prices in one or both markets
change.
Ÿ Offer liquidity on one side. Riskier but less costs than the first strategy involving the arbitrageur offering
liquidity in one or both markets in which they trade.
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Fast Communication
Ÿ Electronic traders and brokers may minimize communication times by minimizing communication
distances and maximizing line speeds.
Ÿ Communication distance = Distance A + Distance of B = Total of two distances that signals must travel
Distance A: Distance between event report site to the computer which will process the information
Distance B: Distance from the computer to the exchange trading system where trader will want to deliver
the order instruction
Electronic Traders and brokers locate their computers as close as possible to exchanges at which they
want to trade to minimize latencies
Ÿ Calculation: Practice of traders placing servers in the same room in which exchange servers
operate
Ÿ Electronic traders and brokers use fastest communication technologies to collect and transmit
information when distance separates the place where information events occur from the places
where traders act on those events.
Ÿ Electronic traders and brokers subscribe to high speed data feeds directly from exchanges and
other data vendors paying at a premium price
Fast Computations
Electronic traders minimize decision making latencies by using several strategies
Ÿ They use very fast computers, run them at fast processing speeds, and store information in fast
memories
Ÿ They use simple and specialized operating systems to maximize efficiency
Algorithms
These represent programmed strategies for filling orders. Algorithms may use simple order, advanced
order or multiple orders to achieve objectives.
Brokers use algorithms to trade small orders or break large order into smaller pieces to reduce price impact.
eg. The volume-weighted average price (VWAP) algorithms aim to achieve a volume-weighted average fill
price that is close to (or better than) the volume-weighted average price of all trades within a period. Buy-
side traders rely on the VWAP algorithm when spreading their orders over time and when obtaining the
average market price within an interval that is acceptable to them or their portfolio managers.
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Ÿ Offer liquidity on both sides. This strategy involves offering liquidity in both markets. This strategy is
the riskiest strategy because arbitrageurs are exposed to substantial price risk when one leg is filled
and the other is not as they wait to complete the second trade
Machine Learning
Involves the use of advanced statistical methods to characterize data structures, particularly relations
among variables. These methods are based on observed empirical regularities rather than on theoretical
principles identified by analysts.
Machine learning is useful when trading problems repeat regularly and often as well as in active financial
markets where stable processes generate vast amounts of data.
Machine learning is not useful when trading becomes extraordinary such as when volatility is extreme.
In such cases data volume is low and so there is little from which machines can learn.
LOS i The risks associated with electronic trading and how regulators mitigate
them
HFT Arms Race: Competition among high-frequency traders (HFTs) has created an arms race in
which each trader tries to be faster than the other. This has increased high-frequency trading
technology costs leading to high entry barriers, natural monopolies and HFTs quitting the market.
Ÿ These costs are ultimately incurred by traders who need to pay these costs.
Ÿ It has been observed that technologies used by HFTs do little to promote market liquidity
Ÿ 2.1
TestThe Creation/Redemption
software Process
thoroughly before using in live trading.
Ÿ Rigorous market access controls so that trades from approved sources enter the electronic order-
matching system
Ÿ Rigorous access controls on software developers so that authorized developers can change software
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Ÿ Electronic traders generating orders and electronic exchanges receiving orders must monitor their
order flow to ensure it meets preset parameter. Brokers must monitor all client orders introduced
into electronic trading systems and avoid practice of clients submitting orders directly into exchange
trading systems or sponsored naked access
Ÿ Exchanges adopt price limits and trade halts to stop trading when prices move too quickly. These
rules halt trading when there is excess demand for liquidity and prevents extreme price movements
when available market liquidity does not match demand.
LOS j Describe abusive trading practices that real-time surveillance of markets may
detect
While the use of real-time surveillance technologies is not consistent across all markets, real-time
surveillance can detect the following behaviours
Front Running
Involves buying in front of anticipated purchases and selling in front of anticipated sales. Front running is
illegal if information concerning a trade is acquired illegally.
Some traders use electronic artificial intelligence systems to identify when traders are filling large orders
by breaking them into small pieces. These traders will trade ahead on the same side with the hope that
they will benefit from a movement in prices caused by large traders filling their orders.
This strategy is legal if information obtained concerning the trade is properly acquired.
Front running increases transaction costs for traders whose orders are front run.
Market manipulation
The practice of producing misleading or false market prices, quotes or fundamental information to
profit from distorting normal market operations.
Market manipulation strategies are generally illegal in most jurisdictions but enforcement is often
difficult because exact infractions can be hard to define.
Ÿ Trading for market impact: Involves a market manipulator incurring substantial trading costs to
raise or lower security prices to influence traders’ perception of value
Ÿ Wash trading: The practice of arranging trades among commonly controlled accounts to create
the impression of market activity at a particular price which may include false reporting of trades.
The purpose being to increase investor’s confidence both in their assessment of security values
and their ability to exit positions without incurring substantial costs
Ÿ Spoofing/layering: A practice in which traders place exposed standing limit orders to convey to
other traders that the market is more liquid that it actually is or suggest a security is under or
overvalued.
ª Risk of spoofing: Spoofing orders may execute before intended orders execute
Ÿ How to manage risk: Keep track of orders in the limit order book ahead of their spoofing orders. If
spoofing orders fill before intended orders, spoofers will cancel the former to prevent them from
executing.
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§ “Pump and dump schemes” Buy stocks to raise prices and encourage momentum traders to
buy. This may be accompanied by rumormongering or wash trading. Bluffers then sell the
stock to momentum traders at higher prices.
§ Short and distorts: Manipulator takes short positions and repurchases shares at lower prices
ª To avoid bluffing financial analysts must base analyses on independent assessments of value
and have a reasonable and adequate basis as required by CFA Institute Standards of
Professional Conduct
Used by manipulators to force disadvantageous trades. A manipulator guns the market by selling quickly
to push down prices with the aim of triggering stop-loss sell orders.
§ In short squeezes, manipulator obtains controls of a significant portion of available lendable stock
shares or bonds
§ To avoid short squeezes, short sellers should ensure lending market has multiple participants
§ Commodity market corners involve manipulators buying many futures contracts and
simultaneously buying deliverable supply of commodities in the spot market and later demands
delivery from shorts who either buy the commodity or repurchase contracts from the manipulator at
high prices.
Ÿ To avoid being caught in an intentional corner, short sellers who do not intend to make delivery should
close their positions early
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Capital Market Sustainability and the Actions of The Relationship between Ethics and
One Regulations
Applying an Ethical ª Establishing an ethical framework for an internal thought process prior
Framework - to deciding to act is a crucial step in engaging in ethical conduct.
ª Utilizing a framework for ethical decision making will help investment
professionals effectively examine their conduct in the context of
conflicting interests
Ethical Commitment ª CFA Institute's goal is to ensure that the organization and its members
of CFA Institute - and candidates develop, promote, and follow the highest ethical
standards in the investment industry
ª There are set of principles that define the overarching conduct CFA
Institute expects from its members and CFA Program candidates
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Code of Ethics
Members and Candidates of CFA Institute must:
Act with integrity, competence, diligence, respect and in an ethical manner
with the public, clients, prospective clients, employers, employees, colleagues
in the investment profession and other participants in the global capital
markets.
Place the integrity of the investment profession and the interests of the clients
above their own personal interests.
Promote the integrity and viability of the global capital markets for the
ultimate benefit of the society.
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Standard I: Professionalism
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Guidance
è Material information - Disclosure would impact the price of security
è If reasonable investor would want the information before making an investment decision
è Prohibition against acting on material nonpublic information extends to securities, swaps, option
contracts and matual funds
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Ÿ Members and Candidates must make reasonable efforts to ensure that anyone subject
to their supervision or authority complies with applicable laws, rules, regulations, and
the Code and Standards
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Ÿ Disclose to clients and prospective clients significant limitations and risks associated
with the investment process
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Ÿ Members and Candidates must not engage in any conduct that compromises the
reputation or integrity of CFA Institute or the CFA designation or the integrity,
validity, or security of CFA Institute programs
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● Must not knowingly participate or assist & must dissociate from any violation of laws, rules or regulations
Recommended :
● Know laws & regulations related to their professional activity in all countries where they work/ conduct
business
● Dissociate or separate from any ongoing client or employee activity if it’s illegal or unethical - in extreme case
they may have to leave the employer
● Encourage their firms to develop and/or adopt a code of ethics, provide information to employees which
highlights applicable laws and regulations, establish written procedures for reporting suspected violation of
laws, regulations or company policies
● In charge of supervision/ investment services- comply with regulations and laws in their country of origin and
where products/services will be sold
Required :
● Use reasonable care & judgement to achieve & maintain independence & objectivity in professional
activities
● Not to offer, solicit or accept any gift, benefit, compensation or any type of consideration that compromises
their own or another’s independence & objectivity
Recommended :
● Investment process must not be influenced by any external sources
● Distinguish gifts from clients & entities seeking influence to the detriment of the client
● Gifts must be disclosed to the member’s employer in any case either prior to acceptance or subsequently
● Don’t get pressurized from sell-side analyst to issue favourable research on current or prospective
investment-banking client in “road shows”
● Effective “firewalls” between research/ investment management & investment banking activities
● Analyst should not be pressured to issue favourable research by the companies they follow
● Do not limit research to discussions with company management. Use sources like suppliers, customers,
competitors
● Portfolio managers should not pressure sell side analysts may have large positions in particular securities
rating downgrade may adversely affect portfolio performance. Their responsibility to respect and foster
intellectual honesty of sell side research
● Members responsible for selecting outside managers should not accept gifts, entertainment or travel that
might be perceived as impairing independence and/or objectivity
● Members employed by credit rating agencies should make sure they prevent undue influence by security
issuing firms, be aware of potential conflict of interest & consider whether independent analysis is
warranted
● Analyst’s compensation for such research should be limited preference is a flat fee without regard to
conclusions or the report’s recommendation
● Best practice analysts pay their own commercial travel while attending informative events or tours
sponsored by the firm being analyzed
● Restrict special cost arrangements. Pay for commercial transportation & hotel charges
● Develop formal policies related to employee purchases of equity, IPOs & private placements
● Appoint a compliance officer, have clear procedures for employee for reporting the unethical behaviour and
violation of regulations
I C : Misrepresentation
Required :
● Must not knowingly make any misrepresentations relating to investment analysis, recommendation, actions
or other professional activities compromises their own or another’s independence & objectivity
Recommended :
● Do not give false impressions in writing, oral or electronic communication
● Models and analysis developed by others at firm property of firm can be used with attribution
● A report written by another analyst employed by the firm cannot be released as another analyst’s work
● Provide employees a written list of firm’s available services and description of the firm’s qualifications
● Information from recognized financial and statistical reporting services need not be cited (Eg Fred, S&P)
● Establish procedures for verifying marketing claims of third parties whose information the firm provides to
clients
I D : Misconduct
Required :
● Must not involve in any professional misconduct, dishonesty, fraud, deceit or commit any act that reflects
adversely on their professional reputations, integrity or competence
Recommended :
● Unethical behaviour in all aspects of M&C’s lives is discouraged
● Do not abuse CFA Institute’s Professional Conduct Program by seeking enforcement of this Standard to
settle personal, political, or other disputes that are not related to professional ethics
● Develop and adopt a code of ethics and make clear that unethical behaviour will not be tolerated
Required :
● Members and Candidates who possess material nonpublic information that could affect the value of an
investment must not act or cause others to act on the information
Recommended :
● Material information if disclosure would impact price of security or if reasonable investor would want the
information before making an investment decision
● Prohibition against acting on material nonpublic information extends to securities, swaps, option contracts
and mutual funds
● Material nonpublic information received while being involved in transactions like investment banking, can
be used for its intended purpose, but must not use the information for any other purpose unless it becomes
public information
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● Mosaic Theory No prohibition on reaching an investment decision through public and non-material
nonpublic information
● Information from internet or social media sources not all of it is considered public information confirm if it is
also available from public sources, such as company press releases or regulatory filings.
● Seeking insight from individuals who have specialized expertise in an industry not act or cause others to act
on any material nonpublic information obtained from these experts until that information has been publicly
● Substantial control of relevant interdepartmental communication through a clearance area like compliance/
legal department
● Monitor & prohibit proprietary trading if a firm possesses material non-public information
● Prohibiting all proprietary trading may send a signal to the market firm should take the contra side of
unsolicited customer trades
II B : Market Manipulations
Required :
● Members and Candidates must not engage in practices that distort prices or artificially inflate trading
volume with the intent to mislead market participants
Recommended :
● Spreading false rumors is prohibited
- deceive the market by distorting the price setting mechanism of financial instruments or
- by securing a controlling position to manipulate the price of a related derivative and/or the asset itself
Required :
● Duty of loyalty to clients & must act with reasonable care & exercise prudent judgment.
● Must act for the benefits of clients & place their client’s interests before their employer’s & their own
interests
Recommended :
● Client interest comes first (but no imposition of fiduciary duty)
● Exercise same level of prudence, judgment & care as in management & disposition of their own interests in
similar circumstances
● Manage pool of assets in accordance with the terms of governing documents (e.g. trust documents)
● Determine the identity of “client’” to whom duty of loyalty is owed (may be individual or beneficiaries in
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case of pension plan or trust)
● Follow any guidelines set by their clients for the management of their assets
● Investment decisions are judged in context of total portfolio rather individual investments
● Conflict arises when client brokerage, “soft dollars” or “soft commissions” are not used for benefits of clients
● Cost-benefit analysis may show that voting all proxies may not be a beneficial strategy for clients
● Submit to each client, at least quarterly, a statement showing funds & securities
● Consider suitability of portfolio relative to client’s needs and circumstances, the investment’s basic
characteristics, or the basic characteristics of the total portfolio
● Diversify
● Disclose conflicts
● Maintain confidentiality
Required :
● Deal fairly and objectively with all clients when providing investment analysis, making investment
recommendations, taking investment action, or engaging in other professional activities
Recommended :
● No discrimination among clients while disseminating recommendations or taking investment action (growth
funds over other funds, discretionary over non discretionary accounts)
● Fairly does not mean equally difference in timings of emails & fax received by clients are normal course of
business
● Different services levels are okay as far as these do not adversely affect any client
● Premium services should be available to all those who are willing to pay for them
● All clients must be given fair opportunity to act upon every recommendation
● Clients unaware of change in recommendation should be advised before the order is accepted
● Clients must be treated fairly in the light of their investment objectives and circumstances
● Both institutional and individual clients must be treated in a fair & impartial manner
● M&C should not take advantage of their position to disadvantage clients (e.g. in IPOs)
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● Firms are encouraged to establish compliance procedures to treat customers & clients fairly
● Limit the no. of people who are aware that a recommendation is going to be disseminated
● Disclose level of services different levels of services are possible for same or different fees
III C : Suitability
Required :
● In an advisory relationship with a client-
● Make a reasonable inquiry into a client’s or prospective clients’ investment experience, risk and return
objectives, and financial constraints prior to making any investment recommendation or taking investment
action and must reassess and update this information regularly
● Determine that an investment is suitable to the client’s financial situation and consistent with the client’s
written objectives, mandates, and constraints before making an investment recommendation or taking
investment action
● Judge the suitability of investments in the context of the client’s total portfolio
● Managing a portfolio to a specific mandate, strategy, or style, they must make only investment
recommendations or take only investment actions that are consistent with the stated objectives and
constraints of the portfolio
Recommended :
● Develop IPS at beginning of the relationship
● Consider whether the use of leverage is suitable for the client or not
● Develop written IPS of each client considering client identification, investor objectives, investor constraints,
performance measurement benchmark (Update IPS at least annually)
● Objectives & constraints should be maintained & reviewed periodically to reflect any changes in clients’
circumstances
● Unsolicited Trade Requests request to purchase a security that is unsuitable which may or may not have a
material effect on the risk characteristics of the client’s total portfolio discussed with the client that it’s
unsuitable
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● If it has minimal impact after discussing with the client about unsuitability follow his firm’s policy with
regard to unsuitable trades
Required :
● When communicating investment performance information > make reasonable efforts to ensure that it is
fair, accurate, and complete
Recommended :
● Avoid misstating performance or misleading clients about investment performance of themselves or their
firms
● Not state or imply the ability to achieve a rate of return similar to that achieved in the past
● Maintain data & records used to calculate the performance being presented
Required :
● Keep information about current, former, and prospective clients confidential unless:
● The information concerns illegal activities on the part of the client or prospective client
Recommended :
● If a client is involved in illegal activities members may have an obligation to report to the authorities
IV A : Loyalty
Required :
● In matters related to their employment act for the benefit of their employer and not deprive their employer
of the advantage of their skills and abilities, divulge confidential information, or otherwise cause harm to
their employer
Recommended :
● Applicable to employees. Independent contractors abide by agreement
● Place client interests above interests of their employer but consider the effects of their actions on firm
integrity and sustainability
● No requirement that the employee put employer interests ahead of family and other personal obligations
balance these obligations with work obligations
● Not have incentive and compensation systems that encourage unethical behaviour
● Independent practice for compensation prior consent of employer describe all aspects of the services,
including compensation, duration and the nature of the activities
● Leaving an Employer continue to act in their employer’s best interests until resignation is effective Activities
which may constitute a violation include:
- Self-dealing
● Employer records on any medium (e.g. home computer, PDA, cell phone) are the property of the firm
● Simple knowledge of names and existence of former clients is generally not confidential
● No prohibition on the use of experience or knowledge gained while with a former employer
● If an agreement exists among employers permitting brokers to take certain client information when leaving
a firm act within the terms of the agreement without violating the Standard
● Adhere to their employers’ policies concerning social media when planning to leave an employer - notifying
clients about employee separations
● Best practice separate social media accounts for personal and professional communication
● Whistleblowing duty to employer violated to protect clients or the integrity of the market and not for
personal gain
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Required :
● Not accept gifts, benefits, compensation, or consideration that competes with or might reasonably be
expected to create a conflict of interest with their employer’s interest unless they obtain written consent
from all parties involved
Recommended :
● Compensation includes both direct & indirect form
● Hired to work part time discuss any arrangements that may compete with their employer’s interest and
abide by any limitations their employer identifies
● Immediately report to employer in written format detailing any proposed compensation and services
IV C : Responsibility of Supervisors
Required :
● Make reasonable efforts to ensure that anyone subject to their supervision or authority complies with
applicable laws, rules, regulations, and the Code and Standards
Recommended :
● Make reasonable efforts to prevent as well as detect violations of laws, rules, regulations or code &
standards by employees
● Adequate compliance system must meet industry standards, regulatory requirements, and the requirements
of the Code and Standards
● Inadequate compliance system bring to attention of firm’s management and recommend corrective action
● If violation respond promptly conduct investigation limit the suspected employee’s activities
● Adopt a code of ethics. Don’t commingle compliance procedures with the firm’s code of ethics
● Be clearly written
● Be easy to understand
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● Outline what conduct is permitted
- Update it as needed
- Review procedures and identify any changes needed to prevent violations in the future
Required :
● Exercise diligence, independence, and thoroughness in analyzing investments, making investment
recommendations, and taking investment actions
● Have a reasonable and adequate basis, supported by appropriate research and investigation, for any
investment analysis, recommendation or action
Recommended :
● Level of research for due diligence depends on product/service offered
● Quantitative Research consider positive & negative results, scenarios which are not typically used to assess
downside risk explain the importance of research and how results were used in decision making process
- Review assumptions
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● Don’t agree with the independent and objective view of the group need not decline to be identified with the
report, as long as there is a reasonable and adequate basis
● Policy requiring that research reports, credit ratings & investment recommendations have a reasonable &
adequate basis
● Develop written guidance for analysts, supervisory analysts & review committees
● Written guidance for computer-based models used in developing, rating & evaluating financial instruments
Required :
● Disclose to clients and prospective clients the basic format and general principles of the investment
processes they use to analyze investments, select securities, and construct portfolios and must promptly
disclose any changes that might materially affect those processes
● Disclose to clients and prospective clients significant limitations and risks associated with the investment
process
● Use reasonable judgment in identifying which factors are important to their investment analyses,
recommendations, or actions and include those factors in communications with clients and prospective
clients
● Distinguish between fact and opinion in the presentation of investment analysis and recommendations
Recommended :
● Always include basic characteristics of security identified
● Update clients regularly about changes in the investment process, risks and limitations newly identified
● Projections from quantitative models and analysis explain the limitations of the model and the assumptions
it uses this judging the uncertainty regarding the estimated investment result
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V C : Record Retention
Required :
● Develop and maintain appropriate records to support their investment analysis, recommendations, actions,
and other investment-related communications with clients and prospective clients
Recommended :
● Maintain records that support conclusion or any investment action
● All communications with clients through any medium, including emails and text messages, are records that
must be retained
● Members who change firms must recreate analysis documentation > not rely on memory or material created
in previous firms
VI A : Disclosure of Conflict
Required :
● Make full and fair disclosure of all matters that could reasonably be expected to impair their independence
and objectivity or interfere with respective duties to their clients, prospective clients, and employer
● Ensure that such disclosures are prominent, are delivered in plain language, and communicate the relevant
information effectively
Recommended :
● Fully disclose to clients, prospects, employers all actual and potential conflicts of interest in order to protect
investors and employers let them judge any potential bias
● Disclosure of :
● Fee arrangements including those in which the firm benefits from investment recommendations
● Give employer enough information to judge the impact of conflict take reasonable steps to avoid conflict
report promptly if conflict occurs
VI B : Priority of Transaction
Required :
● Investment transactions for clients and employers must have priority over investment transactions in which
a Member or Candidate is the beneficial owner
Recommended :
● Prioritize client’s transactions over personal transactions & transactions made on behalf of the member’s
firm
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● Personal transactions may be undertaken after clients and employer have given adequate opportunity and
time to act upon an investment recommendation
● Regular fee-paying family member accounts should not be disadvantaged to client accounts
● Information about pending trades should not be acted on for personal gains
● Preclearance procedures
VI C : Referral Fees
Required :
● Disclose to their employer, clients, and prospective clients, as appropriate, any compensation, consideration,
or benefit received from, or paid to, others for the recommendation of products or services
Recommended :
● Inform employers, clients and prospects of benefits received for referrals of customers and clients >
allowing them to evaluate the full cost of the service as well as any potential partiality
● Update firm at least quarterly regarding nature and value of referral compensation received if firms do not
have clear procedures for approval
Required :
● Not engage in any conduct that compromises the reputation or integrity of CFA Institute or the CFA
designation or the integrity, validity, or security of CFA Institute programs
Recommended :
● Must not engage in any activity that undermines the integrity of CFA charter
● Members volunteering CFA program must not solicit or reveal information about :
● Exam questions
● Scoring of question
VII B : Reference to CFA Institute, the CFA Designation, and the CFA Program
Required :
● Not misrepresent or exaggerate the meaning or implication of membership in CFA institute, holding the CFA
designation or candidacy in CFA program
Recommended :
● Do not over-promise individual competence
● Acceptable : candidate has successfully completed the program in 3 years claiming superior ability is not
permitted
● In written/ oral communications : usage as adjectives or after charterholder’s name. Not as nouns
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