📖 Standard II 测试讲评 — 资本市场诚信

Module: Module 1 — Ethics & Professional Standards Sub-Module: 1.3 Standard II — Integrity of Capital Markets (L017–L028) Progress: 26/560 lessons

Review Overview

This lesson provides a comprehensive review of the 10-question mock test from Lesson 025, covering:

• Standard II(A) — Material Non-Public Information (MNPI)
• Standard II(B) — Market Manipulation

We'll analyze common errors, reinforce key concepts, and take a fresh mini-quiz to lock in the knowledge.

Performance Diagnostic — By Topic

Standard II(A) — MNPI (Q1, Q2, Q4, Q6, Q8) — 5 Questions

Standard II(B) — Market Manipulation (Q3, Q5, Q7, Q9, Q10) — 5 Questions

Common Mistakes & Key Distinctions

🔴 Mistake #1: Assuming "Passive Receipt" of MNPI = No Violation

Q1 Trap: "She only overheard it passively"

The Rule: The source of information does not determine whether there is a violation. The test is: (1) Is the information material? (2) Is it non-public? (3) Did you trade or cause others to trade? Whether you overheard it, received it in an anonymous email, or were directly told — once you know it's MNPI, the duty attaches.

Exam Tip: CFA examiners love "I accidentally heard it" scenarios. The answer is almost always a violation.

🔴 Mistake #2: Confusing "Related Securities Trading" Loophole

Q4 Trap: "She didn't trade the target company — she shorted the competitor instead"

The Rule: Standard II(A) prohibits trading any security whose price would be affected by the MNPI. If Company A is being acquired at a premium, Company B (competitor) may suffer. If you know A will announce bad news, shorting A's suppliers or competitors based on that information is also prohibited.

Memory Hook: "If the information moves the price, the trade is not nice."

🔴 Mistake #3: The "I Told Them Not To" Defense

Q6 Trap: "Mike explicitly instructed the engineer not to disclose non-public information"

The Rule: Instructing someone not to disclose MNPI is good practice (it shows intent to comply), but it does NOT create a safe harbor. Once MNPI is received, the obligation not to trade is absolute. The correct response is: stop the conversation, report to compliance, place the security on a restricted list.

Exam Pattern: CFA questions frequently test this — "good faith effort to avoid" ≠ "defense to trading." Both conditions must be met: (a) avoid receiving MNPI AND (b) if received, don't trade.

🔴 Mistake #4: Over-Applying Manipulation to Legitimate Trading

Q7 Trap: "He profited from false rumors, so he must be guilty"

The Rule: Standard II(B) prohibits participating in manipulation, not observing and reacting to market conditions. David did not create rumors, did not spread them, did not coordinate with manipulators. He observed, analyzed, and traded. That's what analysts do.

Key Distinction: - ❌ Creating false rumors → II(B) violation - ❌ Spreading false rumors (even if you didn't create them) → II(B) violation - ✅ Observing market behavior and making independent judgments → compliant trading

🔴 Mistake #5: Treating "Social Setting" as an Exemption

Q8 Trap: "It was a private dinner party"

The Rule: There is NO "social occasion" exemption to MNPI rules. A CEO disclosing upcoming M&A at a dinner party is selective disclosure. An analyst trading on that information violates II(A). CFA examiners frequently set up "casual settings" to test whether candidates understand that the setting is irrelevant — only the nature of the information matters.

Key Concept Deep Dive: Mosaic Theory (Refresher)

What Mosaic Theory IS: - Gathering extensive public information - Gathering non-material, non-public information (e.g., from conversations where no material facts are disclosed) - Synthesizing these pieces through analysis to reach meaningful investment conclusions

What Mosaic Theory IS NOT: - A defense for trading on a single piece of MNPI - An excuse to solicit inside information piece by piece - A blanket exemption for any information gathered from non-public sources

CFA Exam Litmus Test:

Were the individual pieces of information, standing alone, material and non-public? - If YES → MNPI, cannot use - If NO, but the synthesis is novel → Mosaic Theory, legitimate analysis

Exam Techniques for Ethics Questions

1. The "Most Likely Violated" Approach

CFA Ethics questions typically ask which Standard was most likely violated. A scenario could implicate multiple Standards — pick the one most directly relevant.

Example (Q5): Fabricating and posting fake negative information → II(B) information manipulation AND I(C) misrepresentation. Answer: "Both A and C" (most comprehensive).

2. The "Trap Answer" Pattern

Ethics answer choices often include:

3. Always Check: Material + Non-Public + Trading = Violation

The MNPI violation formula has three elements: 1. Information is material (would affect price and/or investor decision) 2. Information is non-public (not broadly disseminated) 3. You trade or cause others to trade

All three must be present. If information is material but already public → no violation. If non-public but immaterial → no violation. If you have MNPI but don't trade → may still violate if you cause others to trade.

Follow-Up Mini Quiz (5 Questions)

Question 1

An analyst discovers through public satellite imagery that a retailer's parking lots are significantly emptier than last quarter. She publishes a sell recommendation. The stock drops 8%.

Under Mosaic Theory:

A. Violation — satellite imagery is not a traditional public source B. Violation — this is non-public information C. No violation — satellite imagery is publicly available data analyzed to form conclusions D. No violation — but she should have verified with store management first

Question 2

A trader places a very large buy order for a stock, then simultaneously places multiple small sell orders at progressively lower prices in a different account. What manipulative practice is this most similar to?

A. Front running B. Insider trading C. Spoofing / layering D. Marking the close

Question 3

Which of the following would MOST likely be considered material information?

A. The CEO's opinion that "this quarter was challenging" B. Confirmation that the company will miss earnings by 40% C. A competitor opening a new store in the same city D. An analyst's downgrade of the stock from Buy to Hold

Question 4

A research analyst receives an unsolicited tip that Company X will report negative same-store sales. The source is a mid-level employee with no history of providing tips. The analyst:

A. May trade because the source is not high-ranking B. May trade because the tip was unsolicited C. Must assess whether the information is material and non-public before acting D. Should ignore the tip entirely

Question 5

An investment firm's compliance department discovers that a junior analyst has been trading based on MNPI received through an expert network call. The firm's portfolio manager had approved the analyst's trades without knowing the source of the analyst's conviction. Who violated Standard II(A)?

A. Only the junior analyst B. The junior analyst and the expert network C. The junior analyst and possibly the firm (supervisory failure) D. No one, because the portfolio manager acted in good faith

Answer Key & Explanations

Summary