📖 I(C) 应用场景 — 业绩表述与第三方保证

I. Review: Standard I(C) Core Rule

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

Key prohibition areas:

• False statements (misstatement)
• Omission of material facts
• Plagiarism
• Misleading statements

This lesson focuses on two high-frequency application scenarios:

1. Performance Presentation
2. Third-Party Assurance / External Claims

II. Scenario 1: Performance Presentation

2.1 Common Violations

2.2 Proper Performance Presentation Checklist

2.3 GIPS Compliance ≠ Ethical Compliance

III. Scenario 2: Third-Party Assurance & Endorsements

3.1 The Core Issue

You cannot use someone else's name, credential, or endorsement to misrepresent the quality of your own work or product.

3.2 Key Sub-Scenarios

A. Third-Party Research Referencing

B. Claiming Endorsement Without Permission

C. "Guarantee" by Third Parties

3.3 Third-Party Due Diligence — Your Responsibility

You cannot outsource your ethical obligations. Relying on a third party does not excuse misrepresentation:

3.4 Practical Framework: Third-Party Information Vetting

When using third-party data or endorsements, ask:

1. Source: Is the source credible and primary (not secondhand)?
2. Permission: Do you have authorization to cite this?
3. Context: Are you omitting material qualifiers or caveats?
4. Currency: Is the information / endorsement current?
5. Independence: Is the third party independent, or was there compensation?

IV. Integrated Scenario Analysis

V. Practice Quiz

Question 1

Li, an investment advisor, created a marketing brochure stating: "Our balanced portfolio has achieved an average annual return of 9.8% since inception in 2018." The portfolio's inception-to-date return is 9.8%, but this figure is gross of management fees (2.0% per annum). The brochure does not mention fees. Does this comply with Standard I(C)?

A. Yes — the stated return is factually correct based on gross performance
B. Yes — as long as the firm complies with GIPS reporting standards
C. No — the return should be presented net of fees, or the brochure must clearly state it is gross-of-fees
D. No — marketing materials are never permitted to advertise historical returns

Question 2

A fund marketing document includes the following statement: "Recognized by Bloomberg as a Top Emerging Manager." In fact, Bloomberg's ranking list included the fund among 200 "notable new funds" in a single year; the fund was not ranked in the top tier. The "Top Emerging Manager" label was invented by the marketing team. What violation has occurred?

A. No violation — "recognized by Bloomberg" is technically true since the fund appeared in a Bloomberg list
B. Violation of Standard I(C) only — knowingly misrepresenting the nature and level of recognition
C. Violation of Standard I(C) and possibly I(D) — I(C) for the misleading label; I(D) if this reflects a pattern of dishonest conduct
D. Violation of Standard VII(B) — since it involves the CFA Institute reference

Question 3

A research analyst issues a report on Company XYZ, stating: "Based on our proprietary model, Company XYZ is 35% undervalued." The model is actually a third-party template purchased from an external vendor, with only minor adjustments made by the analyst. Under Standard I(C):

A. No violation — the model has been modified, so it is now "proprietary"
B. Violation — the description "proprietary model" is misleading because the core work was done by a third party
C. No violation — as long as the valuation conclusion is independently verifiable
D. Violation — but only if the third-party vendor objects to the "proprietary" label

Question 4

Zhang is a wealth manager whose firm mandates that all marketing materials be approved by the compliance department before distribution. Zhang uses an unapproved one-page summary that states "Average client portfolio return: +15% in 2025" — but this figure excludes accounts opened mid-year (which underperformed) and is calculated by simple average (not time-weighted or money-weighted). The compliance department was never shown this document. What standard is most directly violated?

A. Standard I(C) — misrepresentation of performance through selective data and flawed methodology, compounded by bypassing compliance review
B. Standard IV(C) — responsibilities of supervisors, since Zhang is a manager
C. Standard I(A) — knowledge of the law, because bypassing internal compliance may breach regulatory requirements
D. Both A and C are directly violated

✅ Answer Key & Explanations

Question 1 — Answer: C

Explanation: Gross-of-fees returns without a clear disclosure constitute a misleading omission. Investors must know whether fees have been deducted. I(C) requires performance to be presented fairly — either show net-of-fees or clearly label the figure as gross.

Question 2 — Answer: C

Explanation: Inventing a "Top Emerging Manager" label from a generic Bloomberg listing is a knowing misrepresentation of the nature and level of recognition, violating I(C). If this reflects a pattern of dishonest conduct (e.g., falsifying other claims too), it may also violate Standard I(D) — Misconduct.

Question 3 — Answer: B

Explanation: Describing a purchased third-party template as a "proprietary model" after only minor adjustments is misleading. The core intellectual work was done by the vendor, not the analyst. This misrepresents the origin and quality of the analytical work, violating I(C).

Question 4 — Answer: A

Explanation: The selective exclusion of mid-year accounts and use of an inappropriate averaging method (simple average instead of time-weighted or money-weighted) both misrepresent the true performance — a clear I(C) violation. Bypassing the mandatory compliance review compounds the violation by circumventing internal controls designed to prevent exactly this type of misrepresentation.

📊 Lesson Summary