FIMS study materials
FIMS study resources

FIMS: Ethics, regulation and compliance

FIMS · Work through your exam, one topic at a time.

All guide sections

Ethics, regulation and compliance

Ethics, regulation and compliance tests judgement under conflict: whether you can identify the duty owed, the permitted conduct and the disclosure required.

Core rules

  • Fiduciary duty means loyalty and care; client interests precede the firm's and your own.
  • Material non-public information: do not trade or tip. A mosaic of public information plus independent analysis is permitted.
  • Conflicts must be disclosed and, where possible, eliminated or managed; disclosure alone does not cure an unfair allocation.
  • Fair dealing: order allocation must follow a pre-stated policy, not be decided after results are known.
  • Records and performance must be accurate; no cherry-picking or misrepresentation.

Worked example

A block trade fills in full, but the manager allocates the winners to the top-performing client and the losers to a new account. This breaches fair dealing, because allocation must follow a pre-established method applied consistently, and retroactive allocation based on outcome is prohibited. Had the order filled only partially, a pro-rata allocation consistent with the disclosed policy would be acceptable.

Traps that cost marks

  • Assuming written disclosure makes any conflict acceptable.
  • Treating a small non-cash client gift as harmless.
  • Charging research used for all clients to a single account.
  • Acting on information received in a casual conversation and assuming it is public.