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

An FRM holder is subpoenaed by a regulator, which lawfully requires disclosure of certain confidential client records related to an investigation. Which statement best reflects the GARP Code of Conduct?

Disclosure to the regulator is acceptable to the extent the law or regulation requires it. The GARP Code treats confidentiality as a strong duty but not an absolute one, with a legal-requirement exception that does not extend to wider disclosure such as to the media.

  1. ADisclosure is acceptable to the extent required by law or regulationCorrect
  2. BDisclosure is prohibited under all circumstances because client confidentiality is absolute
  3. CDisclosure is acceptable only after the client has been paid compensation
  4. DDisclosure is acceptable to the regulator and also to the press

Explanation

The confidentiality duty has an exception where disclosure is required by law or regulation. It is not absolute, so the second option is wrong. Compensation is not a condition, and disclosure beyond what is legally required, such as to the press, is not covered by the exception.

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