CFA Level III · Level III Core
Guidance for Standard V: Investment Analysis, Recommendations, and Actions: formula sheet
Key formulas
- Core requirement
- Diligence + Independence + Thoroughness → Reasonable and adequate basis
- Applies to every analysis, recommendation or action. The basis must be supported by appropriate research and investigation.
- Test of compliance
- Compliant if the process supports the conclusion, whatever the outcome
- Investment losses alone are not a violation. A lucky gain with no research can still be a violation.
- Reliance on others
- Use of third-party research or models → make reasonable efforts to check them
- Greater checking is needed when the source is unfamiliar or the work is complex. Blind reliance fails the standard.
- Group work
- A member in a group who disagrees with the group's conclusion should dissociate from it where appropriate. A member who relies on the group's work without dissociating is not in violation if they reasonably believe the group's work has a reasonable and adequate basis.
- Dissociation is the route for a member who disagrees. Reliance without dissociation is acceptable only where the member reasonably believes the group's work is sound.
- Recommended procedures
- Written policies + defined research standards + quantitative-model checks + selection of outside advisers or vendors with care
- Firms should set minimum research requirements and review the reasoning behind recommendations.
- Core rule of Standard V(A)
- Reliance on secondary or third-party research is allowed only after due diligence on its quality
- Using it is fine. Using it unchecked is the violation.
- Due diligence checklist
- Assumptions + Methods and rigor + Data quality + Independence + Conclusion supported by evidence
- Use this list to judge any source in a case.
- Ongoing duty
- Select with care, then review the provider periodically
- A one-time check at selection is not enough if quality may change.
- Responsibility
- Your recommendation is your responsibility, whatever the source
- Citing the provider does not remove your duty.
- Core rule
- Group consensus + reasonable and adequate basis + member comfortable it is sound = member may remain associated
- Disagreeing with the group's conclusion does not by itself breach Standard V(A).
- Dissociation rule
- No reasonable basis, or member cannot support the recommendation = member should ask that their name be removed
- Dissociation means refusing to be associated with the recommendation. It is not a duty to publish a rival view.
- Reasonable basis test
- Diligence + independence + thoroughness, supported by research and investigation
- This is the standard the group work must meet. The test applies to the work, not to whether it matches your opinion.
- Process disclosure
- Disclose the basic format and general principles of the investment process; update clients promptly when it changes materially
- Detail needed is enough to understand the approach, not proprietary secrets.
- Content rule
- Use reasonable judgment to identify the important factors, explain their use, and include significant limitations and risks
- Do not omit a factor that would change the client's view of the recommendation.
- Fact vs opinion
- Fact = verifiable; opinion = judgment or forecast; label them separately
- Presenting a forecast as fact is a violation.
- Scope
- Applies to clients and prospective clients, in all communication formats
- Includes written, oral and electronic communication.
- Core duty
- Develop and maintain appropriate records that support analyses, recommendations, actions and client communications
- Applies to both firm-created and member-created records relating to investment work.
- Recommended retention period
- At least 7 years in the absence of a regulatory requirement (longer if local law requires)
- The Handbook recommends this period. Where law requires a longer period, follow the law.
- Record ownership
- Records created as part of employment = property of the firm
- A departing member does not take originals without the employer's permission.
- Electronic communications
- Business-related emails, texts and social posts = records to be retained
- Use firm-approved channels and follow the firm's capture and storage policy.
- Law link
- Longer local law period: follow the law. Shorter local law period: keep at least 7 years as the stricter practice
- Standard I(A) requires following the stricter of law and the Code and Standards. A shorter local period does not remove the seven-year recommendation.
- V(A) Diligence and Reasonable Basis
- Reasonable and adequate basis + appropriate research and investigation + independent checks of third-party or group work
- Breached when work is thin, a model is used blindly, or someone else's output is accepted without checking. Applies to recommendations and actions.
- V(B) Communication with Clients
- Disclose process + separate fact from opinion + include important factors + state limitations and risks
- Applies to clients and prospective clients. Disclose process changes promptly. Models and their limits must be explained where relevant.
- V(C) Record Retention
- Keep records that support analyses, recommendations, actions and client communications
- Seven years is the recommended minimum unless local law or firm policy requires longer. Records belong to the firm. Electronic communications count.
- Quick distinction V(A) vs V(B)
- V(A) = quality of the work done; V(B) = quality of what is told to the client
- If the problem is shallow research or blind model use, it is V(A). If the problem is what the client was or was not told, it is V(B).
Quick revision
- V(A): exercise diligence, independence and thoroughness, and have a reasonable and adequate basis for recommendations and actions.
- The basis must be supported by appropriate research and investigation.
- Diligence depends on the facts, the type of security and the context, so more risk or complexity means more work.
- Before relying on third-party research, make reasonable inquiry into its assumptions, methods and independence.
- Do not simply copy others' work without checking it.
- In a group, you may stay associated with the group view if you believe it has a reasonable basis, even if you disagree.
- If you think the group view lacks a reasonable basis, you should dissociate from it.
- V(B): disclose the basic format and general principles of your investment process, and promptly tell clients of material changes.
- Separate fact from opinion in reports, and include the factors that are important to your recommendations.
- Tell clients about the limitations and risks of your analysis and recommendations.
- V(C): develop and keep appropriate records supporting your analysis, recommendations, actions and client communications.
- Records belong to the firm, and they may be kept in any medium, written or electronic.
- Absent a regulatory requirement, CFA Institute recommends retaining records for at least seven years.
Common mistakes
- Deciding a violation because the investment lost money. Fix: Judge the research and process. A sound process with a loss is not a violation.
- Saying any use of third-party research is a violation. Fix: Reliance is allowed if you make reasonable efforts to check that the research is sound.
- Thinking any outside research is forbidden or must be redone. Fix: Using it is allowed. You only need a reasonable check of quality and assumptions.
- Assuming a big or well-known provider needs no review. Fix: A good name lowers the depth of review but does not remove it. Periodic checks still apply.
- Thinking any disagreement with the group forces dissociation. Fix: Disagreement on a judgement call is allowed when the basis is reasonable and the member is comfortable.
- Thinking the member must change their own opinion to match consensus. Fix: The Standard does not require agreement. It requires a reasonable basis and honest association.
- Thinking you must reveal the full model or proprietary details Fix: The Standard asks for basic format and general principles only. Detail needs to be enough for understanding.
- Ignoring limitations and risks because the recommendation looks strong Fix: Always check that significant limitations and risks are communicated, such as model or data weaknesses.
- Saying records need to be kept for exactly seven years. Fix: Say the Handbook recommends at least seven years, and longer if local law requires it.
- Thinking a departing member may take their research files. Fix: Records belong to the firm. Take copies only with employer permission and respect confidentiality.
Exam tips
- Look for the one fact that shows the work done: verified or unverified source, tested or untested model. That fact usually decides the answer.
- Never pick an option that judges the decision by profit or loss alone.
- In essays, name the standard, state violation or no violation, and give the deciding fact in one sentence. Extra text earns no extra points.
- When asked for corrective actions, give specific steps such as verifying the source, reviewing model assumptions, or following firm research policy.
- Expect V(A) to appear next to V(B) and the third-party research guidance. Read carefully to see whether the issue is the research or the communication.
- Look for the verb of checking: reviewed, tested, compared. Its absence usually signals a violation.
- Expect a trap where the provider is famous or long used. Reputation alone is not due diligence.
- In essay answers, name the Standard, then give the specific failed check, such as independence or stale assumptions.