Standard III(B) Fair Dealing

21 questions
Question 1 of 21

Ngozi participates in an oversubscribed secondary offering for her clients. Her personal trading account — which she operates separately from client accounts and under a distinct strategy — receives the same pro-rata share assigned to each similarly sized client, and the practice is disclosed on the firm's website. Her conduct is most likely:

Question 2 of 21

Delacroix's firm offers two research tiers: a standard tier included with all advisory accounts and a premium tier available for an additional fee that adds deeper proprietary modeling. Every client is informed of both tiers and may enroll in either. Standard-tier clients receive new recommendations on the same initial distribution as premium-tier clients. The firm's program is most likely:

Question 3 of 21

Svensson has drafted a 'buy' research report scheduled for firm-wide distribution next Monday, pending compliance review. On the preceding Thursday, he hosts a lunch with several of his most profitable clients and previews the purchase recommendation and its supporting rationale in detail. His conduct is most likely:

Question 4 of 21

After approving a new 'sell' call on a mid-cap issuer, Varga calls her three largest institutional clients to walk through the thesis. Thirty minutes after the last call, she sends the same written recommendation by email to the remainder of the firm's client list. Her conduct is most likely:

Question 5 of 21

Chen's firm is allocated fewer shares than it requested in an oversubscribed IPO. Chen distributes the shares pro rata on a round-lot basis to clients for whom the issue is suitable. Two discretionary accounts that had expressed interest are excluded because the issue is inconsistent with their stated investment objectives. Chen's allocation is most likely:

Question 6 of 21

Powell, an analyst, decides to issue a 'buy' recommendation on a small technology firm. The full research report will take two more weeks to clear compliance review, so Powell first releases a one-page summary of the conclusion and core thesis to every client on the firm's distribution list, with the detailed report to follow. Powell's action is most likely:

Question 7 of 21

Under pressure to retain the firm's largest revenue-generating client, Velasquez purchases a block of securities for several accounts without preparing allocation tickets. Several days later, after observing which trades moved favorably and which did not, she allocates the profitable trades to the large client and spreads the losing trades across other accounts. Her conduct is most likely:

Question 8 of 21

Following a material change from 'buy' to 'hold' on a core holding, Park distributes the revised recommendation to every current client of record. She additionally telephones the subset of clients whom she knows acted on the earlier 'buy' call to confirm that they have received and understood the update. Her conduct is most likely:

Question 9 of 21

Farooqi aggregates orders from ten client accounts into a single block trade. The executions span several price points during the day. She assigns each participating account the single volume-weighted average execution price and charges an identical commission rate to all participants. Her allocation is most likely:

Question 10 of 21

At 8:00 a.m., Quinones distributes a new research note containing a 'hold' recommendation to the firm's entire client list. At 12:30 p.m., she hosts a previously scheduled lunch with two long-standing clients and discusses the implications of the note for their specific portfolios. No new opinion, target, or catalyst is shared that is not already in the distributed note. Her conduct is most likely:

Question 11 of 21

In a written report distributed to all clients, Alvarez reiterates a company's publicly indicated quarterly earnings estimate of USD 1.16 per share. Informally, over the phone, he tells his three largest clients that he personally expects an upside surprise and considers the stock a strong buy at current levels. His conduct is most likely:

Question 12 of 21

Kowalski, a junior analyst, is asked to build her firm's online presence. Before her first research report on an auto-sector issuer is distributed to the firm's client list, she posts a brief summary of her 'buy' recommendation to the firm's LinkedIn page, which is followed only by a fraction of the firm's clients. Her post is most likely:

Question 13 of 21

Mendez's firm creates a 'Platinum' research tier offering earlier access to new recommendations for a higher fee. To avoid overwhelming the analyst team, the firm invites only its twenty largest accounts into the Platinum program and does not inform smaller clients that the tier exists. The firm's practice is most likely:

Question 14 of 21

At 9:30 a.m., Johansson's firm downgrades a stock from 'buy' to 'sell' and begins distributing the change. At 9:45 a.m., a client calls the desk wishing to add to the position in reliance on the older 'buy' note. Before accepting the purchase order, the broker informs the client that the recommendation has been changed to 'sell.' The client acknowledges the change and still elects to proceed. The broker's conduct is most likely:

Question 15 of 21

At 9:00 a.m., Ortiz emails a new 'buy' recommendation to every client of the firm. At 10:00 a.m., Ortiz phones the three institutional clients who pay for the firm's premium advisory package to walk them through the valuation model and answer questions. Ortiz's conduct is most likely:

Question 16 of 21

Berger's firm distributes research through a primary channel at a pre-announced time each morning. A small group of clients in remote jurisdictions receives the notes a few hours later because they rely on a batch-relay email service with their preferred delivery schedule. The system is applied consistently to every client based on the delivery channel each client selected at onboarding. The firm's practice is most likely:

Question 17 of 21

Ibrahim, a performance analyst, proposes two internal reports for the CIO: one listing the percentage holdings of common securities across similar client portfolios, and a second comparing the monthly returns of portfolios with similar strategies. Outlier accounts would be flagged for review. Ibrahim's proposal is most likely:

Question 18 of 21

Sato receives a partial fill on a new ten-year bond issue her firm had requested for five clients. The firm's minimum lot size is USD 5,000. A strict pro-rata split of the partial fill would leave two clients with positions below USD 5,000 each, impairing future liquidity. Sato instead allocates so that every participating client receives at least the minimum lot, keeping the split as close as practicable to the requested amounts. Her allocation is most likely:

Question 19 of 21

Madsen is allocating an oversubscribed IPO among her clients. Her mother maintains a discretionary account at Madsen's firm that is managed under the same investment policy template, fee schedule, and allocation algorithm that govern all of the firm's other retail clients. Madsen includes the account in the pro-rata allocation alongside the other clients. Her conduct is most likely:

Question 20 of 21

Tanaka joins a small firm that has no formal procedures for disseminating research recommendations or allocating trades. Observing the gap, she prepares a written proposal for the managing partner outlining a fair-dealing framework — including simultaneous dissemination, documented allocation practices, and periodic account review — and requests approval to adopt it. Her action is most likely:

Question 21 of 21

Rao manages several pension accounts that share access to the same research package funded through brokerage commissions. To reduce the research expense borne by a preferred pension client whose referral he wishes to protect, Rao intentionally increases trading activity in the other pension accounts so the shared research remains funded. His conduct is most likely: