📖 标准 I(C) — 不当陈述（Misrepresentation）

I. Text of Standard I(C)

Members and Candidates must not knowingly make any misrepresentations relating to investment analysis, recommendations, actions, or other professional activities.

II. Core Concept Breakdown

2.1 What Constitutes "Misrepresentation"?

2.2 Key Word: "Knowingly"

• The Standard requires subjective intent — the individual must be aware that the statement is false or misleading
• However, this does not mean "negligence" is acceptable — gross negligence may also constitute a violation
• Reasonable diligence is the test: were reasonable steps taken to ensure accuracy of the statement?

III. Typical Violation Scenarios

3.1 Performance Presentation Violations

Typical behavior:

• Inflating historical investment returns
• Selectively showcasing profitable accounts/trades while hiding losses
• Claiming "guaranteed returns" or "risk-free"
• Presenting simulated performance as actual performance
• Failing to disclose whether fees were deducted from performance figures

3.2 Qualifications & Capability Violations

Typical behavior:

• Referring to oneself as a "CFA" without having earned the Charter
• Exaggerating educational background or work experience
• Claiming "exclusive inside information" or "special access"
• Falsely claiming that performance has been "independently verified by a third party"

3.3 Plagiarism

Typical behavior:

• Directly copying others' research reports without attribution
• Paraphrasing others' research findings without citation
• Using third-party models/data but claiming them as proprietary
• Taking credit for team results as solely personal work

3.4 Guarantees and Promises

Typical behavior:

• Claiming "will definitely outperform the market"
• Making deterministic predictions about future returns
• Claiming a product has "no risk whatsoever"
• Using absolute terms such as "capital guaranteed" or "guaranteed profit"

IV. Compliance Summary

V. Distinguishing from Other Standards

VI. Memory Aid

VII. Practice Quiz (5 Questions)

Question 1

Scenario: Manager Zhang's fund delivered an actual return of 8% last year (after fees). However, the marketing materials state "This fund returned 12% over the past 12 months," based on the pre-fee figure without disclosing the calculation method.

Q: Has Manager Zhang violated Standard I(C)?

A. No violation, because 12% is indeed the portfolio's gross return
B. Violation — failure to disclose fee deduction constitutes a misleading statement
C. No violation, as long as he can explain it when asked
D. Violation, because he should use the 3-year average return

Question 2

Scenario: Analyst Li extensively cited a renowned economist's analytical framework and core arguments in his report, but rewrote them in his own words. The report includes no references or citations at the end.

Q: Has Analyst Li violated Standard I(C)?

A. No violation, because he rewrote it in his own words
B. Violation — he plagiarized others' work without attribution
C. No violation, because the economist's article is publicly available information
D. Violation, but only for the parts directly quoted verbatim

Question 3

Scenario: Mr. Wang passed CFA Level II and currently prints "Wang, CFA Level III Candidate" on his business card. At a client meeting, a client referred to him as a "CFA analyst" and he did not correct them.

Q: Has Mr. Wang violated Standard I(C)?

A. No violation — the business card wording is accurate
B. Violation — the "CFA" text on the business card may mislead others
C. No violation — the misunderstanding was caused by the client
D. Violation — improper business card wording AND failure to correct the client's misunderstanding

Question 4

Scenario: An analyst posts on social media: "Our AI stock-picking model projects over 30% returns next quarter, with 95% historical accuracy." In reality, the model was only backtested on 6 months of data and has never been independently verified.

Q: Which aspects of I(C) has the analyst violated?

A. Only exaggerated claims
B. Only failure to disclose limitations
C. Exaggerated claims + failure to disclose limitations + selective use of data
D. No violation — "projects" implies an estimate, not a guarantee

Question 5

Scenario: Analyst Chen manages portfolios for 10 clients, 3 of which achieved outstanding performance. In the quarterly newsletter, he only presents the performance of these 3 accounts, with a note stating "Representative account performance."

Q: Has Analyst Chen violated Standard I(C)?

A. No violation — he noted that these are "representative accounts"
B. Violation — selective presentation constitutes a misleading statement
C. No violation, as long as the performance figures of the actual accounts are genuine
D. Violation — he should have shown the worst-performing account

✅ Answer Key & Explanations

Question 1 — Answer: B

Explanation: Although 12% is technically a "real" figure, the omission of fee deduction disclosures means investors cannot compare the 12% with the actual post-fee return of 8%. Selectively providing information constitutes a misleading omission, violating I(C).

Question 2 — Answer: B

Explanation: Paraphrasing others' research without attribution still constitutes plagiarism. The CFA Code of Ethics strictly requires that when using others' original analytical frameworks, core arguments, or research methodologies — whether paraphrased or not — the source must be cited. Publicly available information does not mean citation is unnecessary.

Question 3 — Answer: D

Explanation: While "CFA Level III Candidate" on the business card is not inherently a violation (it is factual), if the "CFA" designation is too prominent and may be understood as "CFA Charterholder," it could be misleading. More importantly, when the client misunderstood, he had an obligation to correct it — failure to do so constitutes implied misrepresentation. Option D is the most comprehensive.

Question 4 — Answer: C

Explanation: Multiple violations exist: (1) making a deterministic prediction about future returns ("over 30%") → exaggerated claims; (2) failing to disclose that the model was only backtested for 6 months and never independently verified → omission of material limitations; (3) "95% historical accuracy" based on a very short sample → selective use of data. Despite using "projects," the overall presentation is still misleading.

Question 5 — Answer: B

Explanation: Presenting only the best-performing accounts, regardless of whether labeled "representative," constitutes cherry-picking — a classic I(C) violation. If these 3 accounts were not randomly selected but are the best performers, the term "representative" is itself a misrepresentation. Compliant practice: present the composite performance of all accounts, or at minimum provide the full distribution.

📊 Lesson Summary