Q. Alexandra Zagoreos, CFA, is the head of a government pension plan. Whenever Zagoreos hires a money management firm to work with the pension plan, she finalizes the deal over dinner at a nice restaurant. At these meals, Zagoreos also arranges for the money manager to provide her payments equal to 10% of the management fee the manager receives from the pension plan with no formal documentation of this agreement. Zagoreos keeps half of the payments for her own use and distributes the remainder as cash incentives to a handful of her most trusted staff. Zagoreos least likely violated which of the following CFA Institute Code of Ethics and Standards of Professional Conduct?
- Referral fees.
- Loyalty, Prudence and Care.
- Additional Compensation Arrangements.
Solution
A is correct as the money should not be accepted without receiving written consent from all parties involved; therefore, Zagoreos is in violation of Standard IV(B)–Additional Compensation Arrangements. The manager has acted for her own benefit by receiving compensation that competes with or might reasonably be expected to create a conflict of interest with her employer’s interest without receiving written consent from all parties involved. This action is a violation of Standard III(A)–Loyalty, Prudence, and Care, which requires that members act for the benefit of their clients, and places their client’s interests before their employer’s or their own interests. However, there is no indication that the member has received compensation, consideration, or benefit received from, or paid to, others for the recommendation of products or services and therefore has not violated Standard VI(C) related to referral fees.
