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CFA Level I · CFA Level I Exam

Guidance for Standard II: Integrity of Capital Markets

Standard II has two parts. II(A) bars you from acting or causing others to act on material nonpublic information. II(B) bars practices that distort prices or artificially inflate trading volume to mislead market participants. To solve questions, decide whether the information is material and nonpublic, or whether the action intends to mislead the market.

What this chapter covers

This chapter covers Standard II of the CFA Institute Code of Ethics and Standards of Professional Conduct. It has two standards. Standard II(A) is Material Nonpublic Information. Standard II(B) is Market Manipulation. The chapter also covers the mosaic theory, firewalls and other compliance procedures, and the wider link between ethics, society and the capital markets.

The core idea is simple. Markets work only when participants trust that prices reflect public information and genuine supply and demand. Insider trading and manipulation damage that trust. Each test question asks you to spot the breach, or to spot that no breach has occurred.

This chapter sits inside Ethical and Professional Standards, a topic with a high weight in the exam. It links to Standard I (Professionalism), Standard III (Duties to Clients) and Standard V (Investment Analysis, Recommendations, and Actions). A case about research analysts often touches both II(A) and V. Your work on this chapter pays off in many other ethics questions too.

Ethics is one of the heaviest topics in the Level I exam, and questions are standalone three-option items that reward precise knowledge of the Standards. Standard II produces many scenario questions with fine distinctions, such as material versus immaterial, or public versus nonpublic. These distinctions are learnable. If you master the definitions and the recommended actions, you can pick up reliable marks in a topic where careful reading beats calculation.

Guidance for Standard II: Integrity of Capital Markets: topics in the order to study them

  1. 1Standard II(A): Material Nonpublic InformationStart here because it sets the core definitions of material and nonpublic that every later topic builds on.
  2. 2Mosaic Theory and Public Information AnalysisStudy it next because it shows what analysts may legitimately do, which sharpens the line drawn by II(A).
  3. 3Compliance Procedures: Firewalls and Insider InformationOnce you know the duty, learn the controls firms use to prevent breaches and what you should do if you receive MNPI.
  4. 4Standard II(B): Market ManipulationIt is a separate standard with its own tests, so learn it after the MNPI group is solid.
  5. 5Ethics, Society and the Capital MarketsFinish with the broader context, which ties both standards to market integrity and is easier once the rules are clear.

How to prepare Guidance for Standard II: Integrity of Capital Markets

Treat this chapter as a set of tests you apply to a scenario. Learn the wording, then practise applying it.

  1. Read the text of Standard II(A) and II(B) closely and write each in your own words, keeping the key terms exact.
  2. Learn the two tests for MNPI: is it material (would it affect price or an investor's decision), and is it nonpublic (not yet disseminated widely)?
  3. Work through short scenarios on the mosaic theory. Ask whether the analyst combined public and immaterial nonpublic pieces, or used a material nonpublic piece.
  4. List the compliance tools (firewalls, restricted and watch lists, limits on personal trading) and note what each one prevents.
  5. For II(B), separate information-based manipulation from transaction-based manipulation and test each with the question: was there intent to mislead?
  6. Do timed standalone questions. For each, eliminate the two options that misstate the Standard, then check the last one against the wording.
  7. Review every wrong answer and note which condition you missed, such as materiality, intent or source of the information.

Common mistakes in Guidance for Standard II: Integrity of Capital Markets

  • Treating any nonpublic information as MNPI.

    Fix: Always ask both questions: is it material, and is it nonpublic? Both must be yes.

  • Assuming the mosaic theory allows use of material nonpublic information.

    Fix: Remember the mosaic uses public information and immaterial nonpublic information only. A material nonpublic piece still triggers II(A).

  • Confusing a firewall with a general trading ban.

    Fix: A firewall controls information flow between departments. Restricted lists and trading bans are separate tools, though they work together.

  • Calling any price-moving trade market manipulation.

    Fix: Under II(B), the action must be meant to mislead or distort. A large genuine order that moves price is not a breach on that fact alone.

  • Picking the answer that sounds most cautious rather than the one matching the Standard.

    Fix: Test each option against the exact wording of the Standard and the recommended procedure, and choose the one it supports.

  • Overlooking the duty when MNPI arrives by accident.

    Fix: The duty applies however you received the information. Do not act on it and escalate to compliance.

Last-day revision: Guidance for Standard II: Integrity of Capital Markets

  • II(A): do not act or cause others to act on material nonpublic information.
  • Information is material if its disclosure would likely affect the security's price or an investor's decision to trade.
  • Information is nonpublic until it has been made available to the marketplace.
  • Mosaic theory: an analyst may combine public information with immaterial nonpublic pieces to reach a conclusion.
  • A conclusion drawn from public and immaterial nonpublic information is not a breach, even if the conclusion is material. If a material nonpublic piece was used, II(A) applies.
  • A firewall (information barrier) limits the flow of MNPI between departments.
  • An information barrier (firewall) is the primary tool for preventing the misuse of MNPI. Firms also use restricted and watch lists, limits on personal trading and similar controls alongside it.
  • If you receive MNPI, do not trade on it; ask compliance and encourage the company to disclose it publicly.
  • II(B): do not engage in practices that distort prices or artificially inflate trading volume with intent to mislead.
  • Manipulation can be transaction-based (such as wash trades) or information-based (such as spreading false rumours).
  • Intent to mislead is central to II(B); legitimate trading that moves prices is not manipulation.
  • Market integrity supports trust, efficient capital allocation and the wider economy.

Guidance for Standard II: Integrity of Capital Markets practice questions

Guidance for Standard II: Integrity of Capital Markets in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

Guidance for Standard II: Integrity of Capital Markets: frequently asked questions

What is the difference between Standard II(A) and II(B)?

II(A) deals with using material nonpublic information when trading or advising others to trade. II(B) deals with actions that distort prices or inflate volume to mislead the market. One is about information misuse, the other about deceptive market activity.

What makes information material?

Information is material if its disclosure would probably affect a security's price, or if reasonable investors would want it before making a decision. Its source and reliability matter too. Always test materiality before deciding whether II(A) applies.

Does the mosaic theory protect analysts from insider trading rules?

It protects an analyst whose conclusion is derived only from public information and immaterial nonpublic information, even if the conclusion itself is material. It does not protect any use of a material nonpublic piece. In exam scenarios, check what the analyst actually relied on.

How should I prepare for ethics questions in this chapter?

Learn the Standard wording and the recommended procedures, then practise standalone scenarios under time pressure. Use elimination to remove the two options that go against the Standard. Review each mistake to find the condition you missed.