Learning Outcomes
This article explains how to apply the CFA Institute Code and Standards to research objectivity and independence, including:
- identifying situations where analyst independence is threatened by gifts, compensation structures, issuer-paid research, or pressure from clients, issuers, or investment banking colleagues;
- distinguishing between acceptable, questionable, and clearly prohibited conduct when external parties attempt to influence research conclusions or timing;
- determining when gifts or entertainment must be declined, disclosed, or pre-cleared under firm policy and the Standards;
- evaluating issuer-paid and performance-linked compensation arrangements to ensure they do not bias recommendations or distort analyst incentives;
- formulating appropriate disclosure language for conflicts of interest so that users of research can properly assess potential biases;
- applying the Code and Standards to exam-style scenarios that involve subtle conflicts, competing duties to different clients, or pressure from employers;
- recommending internal controls, information barriers, and review procedures that support objective research within an investment firm;
- deciding when analysts and portfolio managers must escalate issues, dissociate from an activity, or refuse an assignment to preserve independence and comply with the Standards.
CFA Level 2 Syllabus
For the CFA Level 2 exam, you are expected to understand the ethical responsibilities surrounding research objectivity and independence, with a focus on the following syllabus points:
- Recognizing situations that may compromise research independence, including gifts, compensation, and external pressures
- Applying the Code and Standards to ensure independence in analysis, recommendations, and actions
- Disclosing conflicts arising from relationships, compensation structures, or issuer-paid research
- Implementing practices and procedures to prevent violations related to objectivity or independence
- Differentiating between acceptable and unacceptable conduct regarding influence from investment banking, issuers, clients, or others
- Evaluating appropriate compliance measures for research departments and investment firms
Test Your Knowledge
Attempt these questions before reading this article. If you find some difficult or cannot remember the answers, remember to look more closely at that area during your revision.
- An analyst receives significant event tickets from a company she covers, with an expectation of favorable research. What should she do under the Code and Standards?
- Which of the following is most likely a conflict of interest that must be disclosed before issuing investment research? a) Participation in an employer's defined benefit plan b) Compensated issuer-paid research engagement c) Attendance at a public conference
- True or false? Research analysts are permitted to accept gifts contingent on positive future recommendations as long as the gift is disclosed to their employer.
Introduction
Investment professionals must avoid situations where independence and objectivity in research or analysis could be questioned or compromised. The CFA Institute Code and Standards outline clear duties to protect research integrity, requiring members and candidates to use reasonable care and independent judgment, regardless of external pressure or compensation. Understanding and properly handling these conflict situations is critical to maintaining client trust, professional reputation, and compliance with the Standards.
RESEARCH OBJECTIVITY: IDENTIFYING RISKS
Research independence is threatened when external parties attempt to influence an analyst’s recommendations through compensation, gifts, personal relationships, or undue pressure. Pressure may flow from investment banking interests, existing or potential clients, issuer companies, or management.
Key Term: Research objectivity
The principle that investment analysis and recommendations must be based on unbiased judgment and not be compromised by personal or external interests.Key Term: Independence
The state in which an investment professional’s decisions and recommendations are uninfluenced by inappropriate external or internal pressures.
Common Threats to Objectivity and Independence
- Gifts or entertainment from covered companies or clients
- Performance-based compensation not adequately disclosed
- Issuer-paid research or report writing tied to positive recommendations
- Requests by investment banking to alter or delay research
- Pressure from clients or employer to change conclusions
Key Term: Conflict of interest
A situation where a member's or candidate's objectivity is potentially compromised by competing personal, financial, or professional interests.
Ensuring Independence in Research
Members and candidates must use reasonable care, professional judgment, and ensure all communications are based on thorough analysis. Do not promise or imply favorable research in exchange for future business, compensation, or access to management or information.
Illustration
An analyst covering a listed telecom company is invited to a hospitality box at a major sporting event by the company’s investor relations team. The company expects that its new service rollout will be covered positively. The analyst must evaluate whether accepting this invitation could reasonably be expected to compromise her independence or appear to do so.
Worked Example 1.1
An equity analyst is approached by a company she covers, offering her event tickets worth several hundred dollars if she issues a favorable report. What should she do?
Answer:
The analyst should decline the offer. Accepting gifts of significant value from covered companies risks compromising or appearing to compromise research objectivity, and would violate the Code and Standards unless the gift is clearly modest and has no appearance of influencing judgment. If there is any doubt, disclosure and prior approval from the employer is required, but in this instance, declining is best practice.
MANAGING OUTSIDE INFLUENCE: BEST PRACTICES
To manage threats to objectivity, firms and members should:
- Establish a strict policy on accepting gifts and entertainment: allow only token items; require immediate disclosure of anything received.
- Limit analysts' interactions with investment banking and sales staff; install physical and informational firewalls.
- Mandate that all research opinions are based on independently verified analysis, not external input.
- Ensure compensation arrangements, especially for issuer-paid research, are unbiased and not dependent on the recommendation or investment action.
Key Term: Issuer-paid research
Research reports produced at the request of, and paid for by, the company being covered, creating a significant potential conflict if not properly managed and disclosed.Key Term: Disclosure
The act of providing clear, prominent, and plain-language explanation of any potential conflict of interest or influence that could impair independence or objectivity.
Worked Example 1.2
A research analyst writes a company-paid report for a prospective IPO and is told by the client that her future compensation depends on a positive investment recommendation. What must she do?
Answer:
She must refuse the arrangement, as it directly ties compensation to the recommendation, violating research independence. At minimum, she must fully disclose any compensation and the nature of the engagement to her employer and in the resulting research, but the conditional arrangement is not permitted.
Exam Warning
A frequent exam error is failing to recognize that disclosing a conflict is only acceptable if the conduct itself is not prohibited. For example, accepting gifts in return for favorable future analysis violates the Standards regardless of disclosure. Do not confuse disclosure with permission.
IMPLEMENTING COMPLIANCE PROCEDURES
Employers must support research objectivity with suitable policies and systems:
- Written code of ethics and independence policies
- Limits on personal trading and personal investments in covered companies
- Regular training and monitoring for undue influence or pressure
- Committee review of research prior to distribution for evidence of bias
- Immediate escalation process for suspected conflicts or external pressure
Members and candidates must dissociate from inappropriate activity and, if necessary, refuse participation or resign if independence cannot be maintained.
Worked Example 1.3
A portfolio manager is asked to adjust weighting of a security after a client threatens to withdraw business unless his favored stock is overweighted in the model portfolio. Is compliance with the Code and Standards maintained if the manager complies and subsequently discloses the pressure in a note to compliance?
Answer:
No. While disclosure of the attempted influence is correct, succumbing to pressure and adjusting weightings to appease one client at the expense of others breaches the duty of loyalty and violates independence.
Summary
Research independence and objectivity are central requirements under the CFA Institute Code and Standards. Accepting gifts, issuer payments, or succumbing to pressures from external parties can compromise analysis. Best practice is to decline anything that could reasonably appear to influence judgment, fully disclose allowable potential conflicts, and prioritize organizational procedures to support unbiased recommendations.
Key Point Checklist
This article has covered the following key knowledge points:
- Recognition of threats to research objectivity and independence
- Typical sources of conflict: gifts, compensation structures, issuer-paid research
- Required response: decline or disclose as per Standards, never accept conditional arrangements
- Employer policies: code of ethics, clear gift/entertainment limits, firewalls, and committee review
- Personal action: dissociation from unethical influence or pressure, immediate escalation if necessary
- Disclosure does not absolve violation of outright prohibitions, e.g., contingent compensation
Key Terms and Concepts
- Research objectivity
- Independence
- Conflict of interest
- Issuer-paid research
- Disclosure