dual role compliance officer

think i messed this up…you can do both, correct? i had they can’t, but pretty sure this is wrong.

Which question are you talking about? There was one on training - in that I marked the one which said, compliance officer has the responsiblity of training the people.

and more random ethics questions: prop strategies can’t be disclosed for just a “few”? quartelry changes in strategy? tips from management = material nonpublic info? flash report is ok?

no, not training—the transition question.

KRochelli Wrote: ------------------------------------------------------- > and more random ethics questions: > > prop strategies can’t be disclosed for just a > “few”? > I market it as a voilation. > quartelry changes in strategy? > yes, this was correct option > tips from management = material nonpublic info? > I have not marked this one. I marked it complies, as he had asked the analyst to do independent study and it was actually undervalued. > flash report is ok? I believe its ok. I marked it in compliance

no, the analyst was said to use mosaic theory, but i believe talking to management for earnings surprises is clear violation.

KRochelli Wrote: ------------------------------------------------------- > no, the analyst was said to use mosaic theory, but > i believe talking to management for earnings > surprises is clear violation. Ok, you are talking about that question. Yes, for that one, the analyst didn’t had a reasonable bias. I was talking about the first question in first ethics vignette.

KRochelli Wrote: ------------------------------------------------------- > no, the analyst was said to use mosaic theory, but > i believe talking to management for earnings > surprises is clear violation. agree. Mosaic theory only applies to non-material non-public information. unreported higher than expected earning is definitely material.

My two cents…the vignette did not mention higher than expected earnings …just the fact that the earnings would be materially different than what the market is expecting (i.e. maybe higher or lower). IMHO …its a question of reasonable and adequate basis.

gauravku Wrote: ------------------------------------------------------- > KRochelli Wrote: > -------------------------------------------------- > ----- > > and more random ethics questions: > > > > prop strategies can’t be disclosed for just a > > “few”? > > > > I market it as a voilation. > > > quartelry changes in strategy? > > > > yes, this was correct option > > > tips from management = material nonpublic info? > > > I have not marked this one. I marked it complies, > as he had asked the analyst to do independent > study and it was actually undervalued. > > > flash report is ok? > > I believe its ok. I marked it in compliance gauravku-i matched ur responses…hope its correct

i think the issue with the dual compliance officer was that he would still be reporting to the CIO under the structure, and you can’t have the compliance officer reporting to the CIO.

yeah, now i think i’m actually correct…you can’t have the dual reporting responsibility. so was it B?

Buckhead Wrote: ------------------------------------------------------- > i think the issue with the dual compliance officer > was that he would still be reporting to the CIO > under the structure, and you can’t have the > compliance officer reporting to the CIO. i agree w/ u

I just think of small firms that I have worked at before, I have had someone with dual roles (one being compliance), he would report to the CEO for compliance then his other job he had another person to report to. I think it’s perfectly reasonable.

it wasnt a small firm,was it?

rain_maker Wrote: ------------------------------------------------------- > My two cents…the vignette did not mention > higher than expected earnings …just the fact that > the earnings would be materially different than > what the market is expecting (i.e. maybe higher or > lower). IMHO …its a question of reasonable and > adequate basis. Not sure why this matters. The fact that earnings would be different from estimates is a pretty imporant piece of info that would move the stock if others knew. It’s material non-public.

JarJarBinks Wrote: ------------------------------------------------------- > it wasnt a small firm,was it? I don’t think it matters; I could be wrong. But a lot of firms have compliance officers doing other roles…

agree with smarshy. and the flash report is not okay as it is a revision in earnings estimates that included little information to the point where he had to call clients to explain it further. flash report and earnings revision does not mix.

i also said that the dual reporting relationship is not good as one should never report to the CIO. but this could easily be wrong. i don’t think this exact scenario was in the cfai cirriculum.

I thought he reported to both, the CEO for compliance and the CIO for his other role…