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FRM Part I · FRM Exam Part I · GARP Code of Conduct

A risk consultant, who is an FRM, is engaged by Client A to assess its derivative counterparty risks. During the work she learns confidential information about Client A's hedging positions. Client B, a competitor, then asks her for a general view on Client A's strategy. Which response is consistent with the GARP Code of Conduct?

She should decline. The GARP Code obliges members to preserve the confidentiality of information from clients and employers and not disclose it without permission, except where law or regulation requires. Fees, perceived harmlessness or removing a name do not justify disclosure.

  1. AShare only the hedging details that seem commercially harmless
  2. BShare the information if Client B agrees to pay a higher fee
  3. CDecline to share, because confidential information must not be disclosed without consent unless legally requiredCorrect
  4. DShare the information if she removes Client A's name from the discussion

Explanation

Members must keep client information confidential and not use or disclose it except with consent or where required by law or regulation. Judging details as harmless, receiving a fee, or anonymizing still leaves the information identifiable in context. None creates a permitted basis for disclosure.

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