FRM Part I · FRM Exam Part I · GARP Code of Conduct
A risk manager at an asset manager is asked by a former colleague, now at a competitor, to share the internal stress-testing results of a client portfolio so they can 'benchmark methodologies'. The client has not consented and the results identify the client. Which response is most consistent with the GARP Code of Conduct?
The risk manager should decline to share. The GARP Code obliges members to keep client and employer information confidential unless the client consents or disclosure is legally required. The colleague's credential or the format of delivery does not create an exception.
- AShare the results after removing only the client's name, since the figures are anonymous
- BShare the results because the colleague is also an FRM holder bound by the Code
- CDecline to share the information, since client information must be kept confidential unless consent is given or disclosure is legally requiredCorrect
- DShare the results verbally rather than in writing to limit the paper trail
Explanation
The Code requires members to hold information confidential, disclosing it only with permission or where legally required. The colleague's FRM status does not create a right to the data. Removing only the name may still leave the client identifiable, and the delivery method does not change the breach.
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