Standard III(C) Suitability

21 questions
Question 1 of 21

Sokolov manages a small-cap-value pooled fund whose prospectus permits up to 10% in mid-cap names when small-cap liquidity is strained, to protect existing investors. During a liquidity event, Sokolov rotates 7% of the fund into mid-cap value names that match the fund's valuation discipline, documents the liquidity rationale, and communicates the step in the next shareholder letter. Is Sokolov most likely in violation of Standard III(C)?

Question 2 of 21

Larsson is a trustee of a pension plan whose IPS, approved by the plan board, forbids investment in tobacco securities. He is informed by compliance that an external manager has added a tobacco position. Larsson notes the IPS change was recent and allows the position to remain pending the next quarterly trustee meeting. Larsson is a CFA charterholder subject to the Code. Is Larsson most likely in compliance with Standard III(C)?

Question 3 of 21

Adeyemi manages the portfolio of a retired client whose IPS targets a moderate risk profile with aggregate beta near 0.9. To capture specific upside, Adeyemi buys a 3% position in a high-beta semiconductor stock. Viewed in isolation, the position is far riskier than the client's stated tolerance, but the portfolio's overall beta remains within the IPS band. Is Adeyemi most likely in violation of Standard III(C)?

Question 4 of 21

Bruckner advises Nakamura, 45, who has a high risk tolerance and wants aggressive growth, and Okoye, 45, who wants steady returns with low volatility to fund a child's tuition. Bruckner invests 20% of each client's portfolio in zero-yield, small-cap technology equities, noting that both clients earn similar salaries and are the same age. Is Bruckner most likely in compliance with Standard III(C)?

Question 5 of 21

Van Houten manages an external mandate for a pension fund whose IPS was recently amended to exclude investments in tobacco producers based on a beneficiary survey. Van Houten reviews the new IPS, judges tobacco to offer attractive risk-adjusted returns that would help meet pension payouts, and buys a tobacco holding on the rationale that higher returns best serve the beneficiaries' economic interests. Is Van Houten most likely in compliance with Standard III(C)?

Question 6 of 21

Harlow manages a publicly offered small-cap growth fund whose disclosures expressly limit holdings to companies below USD 2 billion market cap. A retail investor, Costa, purchases shares without consulting Harlow. Costa is 68, conservative, and the fund is unsuitable for him. Harlow is aware shares are widely sold to retail channels but has no advisory relationship with Costa. Is Harlow most likely in compliance with Standard III(C)?

Question 7 of 21

Ahmadi serves retail clients at a firm whose internal policies treat written IPS documentation as optional for accounts below a certain size. Ahmadi nonetheless prepares a written IPS for each of her retail clients, documenting risk tolerance, return objectives, liquidity needs, and ESG preferences, and bases her recommendations on those documents. Is Ahmadi most likely in violation of Standard III(C)?

Question 8 of 21

Chen manages a family office whose IPS sets long-term capital preservation and downside-risk mitigation as primary objectives and expressly permits ESG considerations. After financial analysis, Chen finds Park Inc. more attractive on pure financial metrics, but Dong Inc. scores materially higher on ESG factors that Chen believes translate into stronger management quality and reduced regulatory-fine risk. Chen invests in Dong Inc. Is Chen most likely in violation of Standard III(C)?

Question 9 of 21

Rivera advises Tan, whose written IPS prohibits speculative holdings. Tan calls insisting on buying a thinly traded biotech on a tip, representing roughly 0.5% of portfolio value. Rivera explains how the trade deviates from the IPS, warns against it, and obtains Tan's written acknowledgement that the trade is against Rivera's advice and against the IPS. Because the position is immaterial, Rivera does not amend the IPS and executes the trade. Has Rivera most likely violated Standard III(C)?

Question 10 of 21

Ortega, a sell-side equity analyst, publishes a high-conviction buy recommendation on a volatile biotech. Vance, a retail investor with no relationship to Ortega or her firm, reads the report online and buys the stock as 40% of his retirement savings, subsequently losing most of his capital. Ortega did thorough research and the recommendation met her firm's publication standards. Is Ortega most likely in violation of Standard III(C)?

Question 11 of 21

Barlow advises a sophisticated client whose IPS explicitly permits leveraged and derivative instruments subject to stated leverage and liquidity limits. Before adding a leveraged ETF position, Barlow conducts an analysis of the embedded leverage, the secondary-market liquidity under stress, and the fit with the client's total portfolio and IPS limits, documenting the conclusions. Is Barlow most likely in violation of Standard III(C)?

Question 12 of 21

Bernal advises Ikeda, whose IPS mandates capital preservation. Ikeda repeatedly demands that Bernal purchase a leveraged commodity ETF representing 25% of the portfolio and refuses to consider amending the IPS. After several discussions and written warnings, Bernal declines to execute and resigns the advisory engagement. Ikeda complains that Bernal abandoned him. Is Bernal most likely in violation of Standard III(C)?

Question 13 of 21

Quon's long-standing client, a 62-year-old widow, inherits a concentrated stake in a profitable family business equal to roughly five times her managed assets. She directs Quon to hold the position and not to hedge. Quon convenes a full IPS review, amends her written objectives and constraints to reflect the new concentration and her willingness to bear it, and documents the change before executing subsequent rebalancing. Is Quon most likely in violation of Standard III(C)?

Question 14 of 21

Hayashi manages a pooled large-cap income fund. Its prospectus does not mention small-cap equities or start-up companies. Believing the broader market has become overvalued, Hayashi invests a meaningful portion of the fund in small-cap start-ups whose shares are speculative in nature, documenting the rationale in an internal memo. Is Hayashi most likely in compliance with Standard III(C)?

Question 15 of 21

Osei reviews each client's IPS annually on the anniversary of account opening. For one stable retail client whose circumstances have not changed, Osei completes a documented review, confirms no amendments are required, and continues the existing allocation without issuing a new written document. Is Osei most likely in violation of Standard III(C)?

Question 16 of 21

Roussel is CIO of a property and casualty insurer whose IPS limits equity to large-cap listed shares and debt to investment-grade bonds of up to five years' maturity, with all assets to be highly liquid. After extensive analysis, Roussel invests 4% of the portfolio in a private equity seed fund offering strong expected returns but imposing a three-year lockup and a laddered exit schedule thereafter. Total equity remains below the IPS cap. Is Roussel most likely in compliance with Standard III(C)?

Question 17 of 21

Duarte advises Pham, a risk-averse client whose equity portfolio he evaluates in aggregate. Duarte proposes writing covered calls on a portion of the equity holdings to enhance income and partially offset declines, fully explaining the possible outcomes including tax effects and the risk of lost downside protection if prices fall sharply. Pham understands and consents. Is Duarte most likely in violation of Standard III(C)?

Question 18 of 21

Kovacs manages a high-income mutual fund whose prospectus describes the strategy as dividend-producing equities and investment-grade debt. Believing a zero-dividend fintech stock is deeply undervalued and will outperform the fund's benchmark, Kovacs allocates 3% of the fund to it. He discloses the position in the next quarterly letter. Is Kovacs most likely in compliance with Standard III(C)?

Question 19 of 21

Tremblay learns that her client Huang has inherited a sum that quadruples his net worth. Huang tells Tremblay the inheritance will not change his lifestyle, so Tremblay elects not to revisit the IPS, which is scheduled for its annual review in four months, and continues Huang's prior allocation unchanged. Is Tremblay most likely in violation of Standard III(C)?

Question 20 of 21

Palmieri advises Okafor, who refuses to disclose significant assets held at other firms. Palmieri documents the refusal, performs a suitability analysis on only the assets she can see, and recommends a concentrated energy allocation that looks suitable given the portion she advises. It later emerges that Okafor's undisclosed external holdings were heavily energy-weighted, making the overall exposure far riskier than Okafor's stated tolerance. Is Palmieri most likely in violation of Standard III(C)?

Question 21 of 21

Alvarado manages several long-horizon public pension accounts. After her firm introduces a bonus program tied to quarterly performance versus peers, Alvarado shifts the accounts toward high-beta stocks believing the incentive program signals the firm's new risk appetite and without recommending any change to the clients' IPSs. Is Alvarado most likely in compliance with Standard III(C)?