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Standard VII(A) Conduct as Participants in CFA Institute Programs

Updated April 2024
CFA Institute

The Standard

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.

Guidance

Standard VII(A) covers the conduct of CFA Institute members and candidates involved in any CFA Institute program. There is an array of CFA Institute programs beyond the earning the CFA designation that provide additional educational and credentialing opportunities. Standard VII(A) holds members and candidates to high ethical conduct while they are participating in or involved with any CFA Institute program so as not to undermine the public’s confidence in the integrity of those programs. This standard does not require participants in a CFA Institute program to comply with the Code and Standards unless they are a member or candidate otherwise subject to the Code and Standards.

Prohibited conduct 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 to CFA Institute regarding any CFA Institute program.

Confidential CFA Institute Information

CFA Institute is vigilant about protecting the integrity of the content and examination processes of all CFA Institute programs. Participants in these programs are prohibited from disclosing confidential material gained during participation in any program or any exam process. Examples of information that cannot be disclosed by candidates or members include but are not limited to,

  • specific details of questions appearing on an exam and
  • broad topical areas and formulas tested or not tested on the exam.

All aspects of an exam for any CFA Institute program 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 nonconfidential information or material with others or in study groups in preparation for an exam.

Many candidates for the CFA designation use online services as part of their exam preparations. CFA Institute actively polices blogs, forums, and related social networking groups for dissemination of confidential information. The organization works to promptly address or remove any and all material that violates exam or other rules, laws, or regulations. Candidates, members, and the public are encouraged to report suspected violations to CFA Institute.

The rules, regulations, and policies for CFA Institute programs define additional allowed and disallowed actions concerning the programs and examinations. Violating any of the testing policies constitutes a violation of Standard VII(A). The policies for CFA Institute programs are posted on the CFA Institute website (www.cfainstitute.org).

Volunteers with CFA Institute Programs

Members participating as volunteers in CFA Institute programs are often exposed to confidential material. Standard VII(A) prohibits members from offering, soliciting, or disclosing confidential material gained while volunteering to unauthorized personnel or those outside the organization. Examples of information that must not be shared by members involved in developing, administering, or grading 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.

Expressing an Opinion

Standard VII(A) does not cover expressing opinions regarding CFA Institute or its 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 confidential information about exam content, including any actual exam questions and information about subject matter covered or not covered in an exam.

Application of the Standard

    Nero, a candidate for the CFA designation, recently found what appears to be a copy of the Level II CFA® exam. Although he is not sure whether it is authentic, he posts some of the questions in an online chatroom frequented by other candidates for the CFA designation. Two other Level II candidates in the chatroom ask Nero to post more questions, which he does. All three use the questions to prepare for their upcoming exam.

    Outcome: 
    Nero and the two candidates violated Standard VII(A). By giving information about the CFA exam questions to two candidates, Nero provided an unfair advantage to the two candidates and undermined the integrity and validity of the Level II CFA exam as an accurate measure of the knowledge, skills, and abilities necessary to earn the right to use the CFA designation. By soliciting and accepting the information, the two other candidates also compromised the integrity and validity of the Level II CFA exam and undermined the ethical framework that is a key part of the designation.

    Chiu is a candidate for the CFA designation and is registered to take the Level I CFA exam during the upcoming open exam window. As the date gets closer, Chiu realizes that she is not prepared to take the exam. According to CFA Institute policies in effect at the time, Chiu can request a Paid Deferral, but she notices that the Emergency Deferral option is free, so she files an Emergency Deferral request claiming that her uncle died. CFA Institute denies her request since the death of an uncle is not a valid basis for an Emergency Deferral under the current rules. In response, Chiu files a second request claiming that her mother died. The death certificate she submits with her new request is identical to her first request, except the name of the deceased has been changed. Later, Chiu admits that there had been no deaths and that the documentation was altered in an attempt to obtain an Emergency Deferral to save money.

    Outcome: 
    By filing a fraudulent request for an Emergency Deferral, Chiu violated rules of the CFA® Program and compromised the integrity of the CFA exam. As a result, her conduct violated Standard VII(A), in addition to Standard I(C) Misrepresentation.

    Hermosa is a candidate for the CFA designation and is registered to take the Level III CFA exam at a test center in his city. On his scheduled exam day, he arrives at the test center. During the check-in process, he refuses to cooperate with the proctor when asked to show that his pants pockets are empty. He becomes agitated, shouts profanity, throws his passport at the proctor, and threatens her with bodily harm. Several other CFA candidates in the test center at the time complain that the incident interrupted their testing experience and that they were concerned for their safety as a result of Hermosa’s conduct.

    Outcome: 
    Hermosa’s conduct violated Standard VII(A) because he violated testing rules and compromised the integrity and security of the CFA exam.

    Yu is a candidate for the CFA designation and is registered to take the Level I CFA exam. She has difficulty remembering formulas, so prior to entering the computer-based testing (CBT) center, she writes several formulas on a piece of paper and hides it in one of her shirt sleeves. During the exam, a proctor notices Yu removing the paper from her sleeve. The proctor approaches Yu and confiscates the paper.

    Outcome: 
    Because Yu took written information into the CBT exam room, her conduct violated the testing rules and compromised the security and integrity of the CFA exam and the validity of her exam performance. Therefore, she violated Standard VII(A).

    Sharma is a candidate for the CFA designation. He is at a CBT center taking the Level II CFA exam. The testing rules prohibit looking at other candidates’ screens. Sharma’s mind wanders during the exam, and he briefly reminisces about the past—when the exams were on paper instead of on a computer. He wonders if his test is the same as that of the test taker sitting next to him, who is also taking the Level II CFA exam. He looks multiple times at the computer screen of the test taker next to him. His conduct is observed by a CBT proctor and is captured by video surveillance.

    Outcome: 
    Sharma’s conduct violated Standard VII(A) because he violated testing rules and compromised the validity, integrity, and security of the CFA exam.

    After completing the Level II CFA exam, Rossi posts online about her experience. Her post reads, “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?”

    Outcome: 
    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 exam content covered on the exam and areas not covered, however, she did violate Standard VII(A). 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 exam.

    Level I candidate Gagne has been a frequent visitor to an internet forum designed specifically for candidates for the CFA designation. The week after completing the Level I CFA exam, Gagne and several others begin a discussion thread on the forum about the most challenging questions and attempt to determine the correct answers.

    Outcome: 
    Gagne violated Standard VII(A) by providing confidential exam information, which compromises the integrity of the exam process. In trying to determine correct answers to specific questions, the group’s discussion included question-specific details considered to be confidential.

    CFA4Sure is a company that produces test-preparation materials for CFA Program candidates. Many candidates register for and use the company’s products. The day after the CFA exam, CFA4Sure sends an email to all its customers asking them to share with the company the hardest questions from the exam so that CFA4Sure can better prepare its customers for the next exam administration. Pena emails a summary of the questions she found most difficult on the exam.

    Outcome: 
    Pena violated Standard VII(A) by disclosing 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 undermined 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 violated Standard VII(A).

    As a condition of participating in grading CFA exams, 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 process, Whitcomb tells several colleagues who are candidates for the CFA designation which question he graded. He also discusses the guideline answer and adds that few candidates scored well on the question.

    Outcome: 
    Whitcomb violated Standard VII(A) by disclosing information related to a specific question on the exam, which compromised the integrity of the exam process.

    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 local 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.

    Outcome: 
    By using his volunteer position at CFA Institute to benefit himself and his clients, Ramirez is compromising the reputation and integrity of CFA Institute and thus is violating Standard VII(A).

    Warrenski is a member of the CFA Institute GIPS® Standards Technical Committee, which provides technical oversight and guides development of the GIPS standards. As a member of the 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 committee membership will allow her to better assist them in keeping up with changes to the GIPS standards and facilitating their compliance with the changes.

    Outcome: 
    Warrenski used her association with the GIPS Standards Technical Committee to promote her firm’s services to clients and potential clients. In stating that her volunteer position at CFA Institute provides a strategic business advantage over competing firms and implying to clients that she would use confidential information to further their interests, Warrenski compromised the reputation and integrity of CFA Institute and thus violated Standard VII(A). She may factually state her involvement with the committee but cannot infer any special advantage to her clients from such participation.

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