Standards of Practice Guidance 2014
Standard VII(A) Conduct as Participants in CFA Institute Programs
Updated January 2019
Members and Candidates must not engage in any conduct that compromises the reputation or integrity of CFA Institute or the CFA designation or the integrity, validity, or security of CFA Institute programs.
Test your understanding of Standard VII(A)
- Application of the Standard
- Example 1 (Sharing Exam Questions)
- Example 2 (Bringing Written Material into Exam Room)
- Example 3 (Writing after Exam Period End)
- Example 4 (Sharing Exam Content)
- Example 5 (Sharing Exam Content)
- Example 6 (Sharing Exam Content) (Updated January 2019)
- Example 7 (Discussion of Exam Grading Guidelines and Results)
- Example 8 (Compromising CFA Institute Integrity as a Volunteer)
- Example 9 (Compromising CFA Institute Integrity as a Volunteer)
Standard VII(A) covers the conduct of CFA Institute members and candidates involved with the CFA Program and prohibits any conduct that undermines the public’s confidence that the CFA charter represents a level of achievement based on merit and ethical conduct. There is an array of CFA Institute programs beyond the CFA Program that provide additional educational and credentialing opportunities, including the Certificate in Investment Performance Measurement (CIPM) Program and the Claritas Investment Certificate. The standard’s function is to hold members and candidates to a high ethical criterion while they are participating in or involved with any CFA Institute program. Conduct covered includes but is not limited to
- Giving or receiving assistance (cheating) on any CFA Institute examinations;
- Violating the rules, regulations, and testing policies of CFA Institute programs;
- Providing confidential program or exam information to candidates or the public;
- Disregarding or attempting to circumvent security measures established for any CFA Institute examinations;
- Improperly using an association with CFA Institute to further personal or professional goals; and
- Misrepresenting information on the Professional Conduct Statement or in the CFA Institute Continuing Education Program.
Confidential Program Information
CFA Institute is vigilant about protecting the integrity of CFA Institute programs’ content and examination processes. CFA Institute program rules, regulations, and policies prohibit candidates from disclosing confidential material gained during the exam process.
Examples of information that cannot be disclosed by candidates sitting for an exam include but are not limited to
- Specific details of questions appearing on the exam and
- Broad topical areas and formulas tested or not tested on the exam.
All aspects of the exam, including questions, broad topical areas, and formulas, tested or not tested, are considered confidential until such time as CFA Institute elects to release them publicly. This confidentiality requirement allows CFA Institute to maintain the integrity and rigor of exams for future candidates. Standard VII(A) does not prohibit candidates from discussing non-confidential information or curriculum material with others or in study groups in preparation for the exam.
Candidates increasingly use online forums and new technology as part of their exam preparations. CFA Institute actively polices blogs, forums, and related social networking groups for information considered confidential. The organization works with both individual candidates and the sponsors of online or offline services to promptly remove any and all violations. As noted in the discussion of Standard I(A)–Knowledge of the Law, candidates, members, and the public are encouraged to report suspected violations to CFA Institute.
Additional CFA Program Restrictions
The CFA Program rules, regulations, and policies define additional allowed and disallowed actions concerning the exams. Violating any of the testing policies, such as the calculator policy, personal belongings policy, or the Candidate Pledge, constitutes a violation of Standard VII(A). Candidates will find all of these policies on the CFA Institute website. Exhibit 2 provides the Candidate Pledge, which highlights the respect candidates must have for the integrity, validity, and security of the CFA exam.
Members may participate as volunteersin various aspects of the CFA Program. Standard VII(A) prohibits members from disclosing and/or soliciting confidential material gained prior to or during the exam and grading processes with those outside the CFA exam development process.
Examples of information that cannot be shared by members involved in developing, administering, or grading the exams include but are not limited to
- Questions appearing on the exam or under consideration,
- Deliberation related to the exam process, and
- Information related to the scoring of questions.
Members may also be asked to offer assistance with other CFA Institute programs, including but not limited to the CIPM and Claritas programs. Members participating in any CFA Institute program should do so with the same level of integrity and confidentiality as is required of participation in the CFA Program.
Expressing an Opinion
Standard VII(A) does not cover expressing opinions regarding CFA Institute, the CFA Program, or other CFA Institute programs. Members and candidates are free to disagree and express their disagreement with CFA Institute on its policies, its procedures, or any advocacy positions taken by the organization. When expressing a personal opinion, a candidate is prohibited from disclosing content-specific information, including any actual exam question and the information as to subject matter covered or not covered in the exam.
Exhibit 2: Sample CFA Program Candidate Pledge
As a candidate in the CFA Program, I am obligated to follow Standard VII(A) of the CFA Institute Standards of Professional Conduct, which states that members and candidates must not engage in any conduct that compromises the reputation or integrity of CFA Institute or the CFA designation or the integrity, validity, or security of the CFA exam.
- Prior to this exam, I have not given or received information regarding the content of this exam. During this exam, I will not give or receive any information regarding the content of this exam.
- After this exam, I will not disclose ANY portion of this exam and I will not remove ANY exam materials from the testing room in original or copied form. I understand that all exam materials, including my answers, are the property of CFA Institute and will not be returned to me in any form.
- I will follow ALL rules of the CFA Program as stated on the CFA Institute website and the back cover of the exam book. My violation of any rules of the CFA Program will result in CFA Institute voiding my exam results and may lead to suspension or termination of my candidacy in the CFA Program.
Application of the Standard
(Example 6 updated January 2019)
Example 1 (Sharing Exam Questions):
Travis Nero serves as a proctor for the administration of the CFA examination in his city. In the course of his service, he reviews a copy of the Level II exam on the evening prior to the exam’s administration and provides information concerning the exam questions to two candidates who use it to prepare for the exam.
Comment: Nero and the two candidates have violated Standard VII(A). By giving information about the exam questions to two candidates, Nero provided an unfair advantage to the two candidates and undermined the integrity and validity of the Level II exam as an accurate measure of the knowledge, skills, and abilities necessary to earn the right to use the CFA designation. By accepting the information, the candidates also compromised the integrity and validity of the Level II exam and undermined the ethical framework that is a key part of the designation.
Example 2 (Bringing Written Material into Exam Room):
Loren Sullivan is enrolled to take the Level II CFA examination. He has been having difficulty remembering a particular formula, so prior to entering the exam room, he writes the formula on the palm of his hand. During the afternoon section of the exam, a proctor notices Sullivan looking at the palm of his hand. She asks to see his hand and finds the formula.
Comment: Because Sullivan wrote down information from the Candidate Body of Knowledge (CBOK) and took that written information into the exam room, his conduct compromised the validity of his exam performance and violated Standard VII(A). Sullivan’s conduct was also in direct contradiction with the rules and regulations of the CFA Program, the Candidate Pledge, and the CFA Institute Code and Standards.
Example 3 (Writing after Exam Period End):
At the conclusion of the morning section of the Level I CFA examination, the proctors announce, “Stop writing now.” John Davis has not completed the exam, so he continues to randomly fill in ovals on his answer sheet. A proctor approaches Davis’s desk and reminds him that he should stop writing immediately. Davis, however, continues to complete the answer sheet. After the proctor asks him to stop writing two additional times, Davis finally puts down his pencil.
Comment: By continuing to complete his exam after time was called, Davis has violated Standard VII(A). By continuing to write, Davis took an unfair advantage over other candidates, and his conduct compromised the validity of his exam performance. Additionally, by not heeding the proctor’s repeated instructions, Davis violated the rules and regulations of the CFA Program.
Example 4 (Sharing Exam Content):
After completing Level II of the CFA exam, Annabelle Rossi posts on her blog about her experience. She posts the following: “Level II is complete! I think I did fairly well on the exam. It was really difficult, but fair. I think I did especially well on the derivatives questions. And there were tons of them! I think I counted 18! The ethics questions were really hard. I’m glad I spent so much time on the Code and Standards. I was surprised to see there were no questions at all about IPO allocations. I expected there to be a couple. Well, off to celebrate getting through it. See you tonight?
Comment: Rossi did not violate Standard VII(A) when she wrote about how difficult she found the exam or how well she thinks she may have done. By revealing portions of the CBOK covered on the exam and areas not covered, however, she did violate Standard VII(A) and the Candidate Pledge. Depending on the time frame in which the comments were posted, Rossi not only may have assisted future candidates but also may have provided an unfair advantage to candidates yet to sit for the same exam, thereby undermining the integrity and validity of the Level II exam.
Example 5 (Sharing Exam Content):
Level I candidate Etienne Gagne has been a frequent visitor to an internet forum designed specifically for CFA Program candidates. The week after completing the Level I examination, Gagne and several others begin a discussion thread on the forum about the most challenging questions and attempt to determine the correct answers.
Comment: Gagne has violated Standard VII(A) by providing and soliciting confidential exam information, which compromises the integrity of the exam process and violates the Candidate Pledge. In trying to determine correct answers to specific questions, the group’s discussion included question-specific details considered to be confidential to the CFA Program.
Example 6 (Sharing Exam Content):
CFA4Sure is owned by Terry Macomb. The company produces test-preparation materials for CFA Program candidates and recently joined the Approved Prep Provider Program. To get approved into the program, Macomb agreed to develop a substantial portion of the business’s course content and not ask candidates to share test questions or topics with CFA4Sure after an exam. (Updated January 2019)
Many candidates register for and use the company’s products. After each CFA examination, Macomb sends an e-mail to all customers thanking them for their business and wishing them success. Additionally, he asks them to share the hardest questions from the exam so that CFA4Sure can better prepare its customers for the next exam administration. Marisol Pena, a level II candidate in the CFA Program, e-mails a summary of the questions she found most difficult on the exam. (Updated January 2019)
Comment: Pena has violated Standard VII(A) by disclosing a portion of the exam questions. The information provided is considered confidential until publicly released by CFA Institute. CFA4Sure is likely to use such feedback to refine its review materials for future candidates. Pena’s sharing of the specific questions undermines the integrity of the exam while potentially making the exam easier for future candidates.
If the CFA4Sure employees who participated in the solicitation of confidential CFA Program information are CFA Institute members or candidates, they also have violated Standard VII(A).
See Also Standard I(D), which Macomb has violated for being dishonest to his agreement in the Prep Provider Program. (Added January 2019)
Example 7 (Discussion of Exam Grading Guidelines and Results):
Prior to participating in grading CFA examinations, Wesley Whitcomb is required to sign a CFA Institute Grader Agreement. As part of the Grader Agreement, Whitcomb agrees not to reveal or discuss the exam materials with anyone except CFA Institute staff or other graders. Several weeks after the conclusion of the CFA exam grading, Whitcomb tells several colleagues who are candidates in the CFA Program which question he graded. He also discusses the guideline answer and adds that few candidates scored well on the question.
Comment: Whitcomb violated Standard VII(A) by breaking the Grader Agreement and disclosing information related to a specific question on the exam, which compromised the integrity of the exam process.
Example 8 (Compromising CFA Institute Integrity as a Volunteer):
Jose Ramirez is an investor-relations consultant for several small companies that are seeking greater exposure to investors. He is also the program chair for the CFA Institute society in the city where he works. Ramirez schedules only companies that are his clients to make presentations to the society and excludes other companies.
Comment: Ramirez, by using his volunteer position at CFA Institute to benefit himself and his clients, compromises the reputation and integrity of CFA Institute and thus violates Standard VII(A).
Example 9 (Compromising CFA Institute Integrity as a Volunteer):
Marguerite Warrenski is a member of the CFA Institute GIPS Executive Committee, which oversees the creation, implementation, and revision of the GIPS standards. As a member of the Executive Committee, she has advance knowledge of confidential information regarding the GIPS standards, including any new or revised standards the committee is considering. She tells her clients that her Executive Committee membership will allow her to better assist her clients in keeping up with changes to the Standards and facilitating their compliance with the changes.
Comment: Warrenski is using her association with the GIPS Executive Committee to promote her firm’s services to clients and potential clients. In defining her volunteer position at CFA Institute as a strategic business advantage over competing firms and implying to clients that she would use confidential information to further their interests, Warrenski is compromising the reputation and integrity of CFA Institute and thus violating Standard VII(A). She may factually state her involvement with the Executive Committee but cannot infer any special advantage to her clients from such participation.
About the Author(s)
CFA Institute is the global association of investment professionals that sets the standard for professional excellence and credentials. The organization is a champion of ethical behavior in investment markets and a respected source of knowledge in the global financial community. Our aim is to create an environment where investors’ interests come first, markets function at their best, and economies grow.