CPH — CSI Conduct and Practices Handbook Quick Review
High-yield Quick Review for the Canadian Securities Institute CSI Conduct and Practices Handbook (CPH), covering conduct, KYC, suitability, conflicts, trading, complaints, and compliance.
Quick Review for CPH
This independent quick review is for candidates preparing for the Canadian Securities Institute exam CSI Conduct and Practices Handbook (CPH), exam code CPH. Use it to refresh the highest-yield conduct and compliance concepts before moving into topic drills, mock exams, and detailed explanations.
Exam mindset: CPH questions often test judgment. The strongest answer usually protects the client, preserves market integrity, avoids or controls conflicts, escalates compliance issues, and documents the decision.
High-Yield CPH Decision Rules
| If the scenario involves… | Think first about… | Best exam instinct |
|---|---|---|
| A client recommendation | KYC, KYP, suitability, conflicts | Do not recommend until facts are current and product risks are understood |
| A client order that seems unsuitable | Clarify, warn, document, escalate if needed | “Unsolicited” does not eliminate all duties |
| Non-public information | Insider trading, tipping, confidentiality | Do not trade, recommend, or pass along the information |
| A complaint | Prompt escalation and recordkeeping | Do not handle privately or promise a result |
| A conflict of interest | Avoid, control, disclose, client’s interest | Disclosure alone may not be enough |
| Discretion over trades | Authority, account approval, supervision | Do not exercise discretion without proper authorization |
| Marketing or social media | Fair, balanced, approved communication | Avoid guarantees, misleading claims, cherry-picked performance |
| Vulnerable client concerns | Capacity, undue influence, trusted contact concepts | Escalate and follow firm procedures |
| Account opening | Identity, capacity, KYC, risk profile, objectives | Incomplete onboarding can contaminate later suitability |
| Suspicious money movement | AML/ATF, sanctions, source of funds | Escalate through firm reporting channels |
Regulatory Framework: Know the Roles
CPH is less about memorizing one isolated rule and more about understanding how registrants, dealers, regulators, and clients interact.
| Participant | Practical role in CPH scenarios | Common exam trap |
|---|---|---|
| Canadian Securities Institute | Official provider of the CSI Conduct and Practices Handbook (CPH) exam | Do not confuse education provider role with dealer supervision |
| Securities regulators | Oversee securities laws and registration framework | Assuming one firm policy overrides securities law |
| Self-regulatory organization / industry regulator | Sets and enforces conduct, supervision, and business rules for member firms and Approved Persons where applicable | Ignoring industry conduct rules because “the client agreed” |
| Dealer member / firm | Supervises representatives, accounts, trades, complaints, records, and compliance systems | Thinking responsibility sits only with the individual representative |
| Registered representative / advisor | Deals with clients, gathers KYC, makes recommendations, handles orders, documents and escalates issues | Treating client relationship management as separate from compliance |
| Client | Provides information, gives instructions, receives disclosures, makes decisions | Assuming the client’s consent cures misrepresentation, unsuitable advice, or conflicts |
Core Conduct Principles
The “CPH default answer” pattern
When two answer choices seem plausible, prefer the one that does more of the following:
- Protects the client’s interest
- Uses current and complete client information
- Understands the product before recommending it
- Identifies conflicts early
- Avoids misleading statements
- Escalates to supervision or compliance
- Creates a clear record
- Preserves market integrity
- Does not bypass firm procedures
- Does not rely on informal shortcuts
Professional conduct themes
| Theme | What it means in exam terms |
|---|---|
| Fair dealing | Treat clients honestly, fairly, and in good faith |
| Competence | Do not recommend or discuss products beyond your understanding or approval |
| Diligence | Investigate, clarify, and document before acting |
| Confidentiality | Protect client information and material non-public information |
| Integrity | Do not mislead clients, regulators, the firm, or the market |
| Accountability | Escalate issues instead of hiding, delaying, or informally resolving them |
Client Relationship Lifecycle
Quick map
| Stage | High-yield duties | CPH-style risk |
|---|---|---|
| Prospecting | Fair communication, no misleading claims, proper use of titles | Overstating credentials or implying guaranteed results |
| Account opening | Identity, authority, KYC, disclosures, conflicts, account approval | Incomplete or stale information |
| Recommendation | KYP, suitability, costs, risks, alternatives, conflicts | Selling a product because it is available or profitable |
| Order handling | Client instructions, suitability concerns, best execution, priority, records | Treating an order as “safe” because it is unsolicited |
| Ongoing relationship | KYC updates, account reviews when required, communication records | Failing to reassess after a material client change |
| Complaints / issues | Prompt escalation, documentation, cooperation | Private settlement or informal promises |
| Account closure / transfer | Timely processing, records, unresolved issues | Delaying action due to compensation or conflict |
KYC, KYP, and Suitability
The three-part chain
| Concept | Key question | Candidate memory cue |
|---|---|---|
| KYC — Know Your Client | Who is this client, and what do they need? | Client facts |
| KYP — Know Your Product | What is this product or strategy, including costs and risks? | Product facts |
| Suitability | Does the product or strategy fit this client now? | Match the two |
If any link is weak, the recommendation is weak.
KYC: high-yield client facts
| KYC area | What to capture or understand | Common mistake |
|---|---|---|
| Identity and legal capacity | Who the client is and who can act for the account | Taking instructions from an unauthorized person |
| Employment / business | Income source, stability, industry exposure, insider status | Ignoring employer restrictions or insider concerns |
| Financial situation | Income, assets, liabilities, liquidity needs | Looking only at net worth and ignoring cash flow |
| Investment knowledge | Experience with securities, leverage, complexity | Assuming wealth equals sophistication |
| Objectives | Growth, income, capital preservation, speculation, liquidity | Using vague objectives that do not guide recommendations |
| Time horizon | When funds are needed | Recommending illiquid or volatile products for short-term needs |
| Risk tolerance | Willingness to accept volatility or loss | Recording “high risk” because the client wants high returns |
| Risk capacity | Ability to absorb loss financially | Ignoring age, income stability, debts, dependants, and horizon |
| Tax considerations | Taxable versus registered account issues, income needs | Treating tax as the only driver of suitability |
| Concentration | Exposure to one issuer, sector, employer, strategy, or product type | Suitable security, unsuitable portfolio concentration |
Risk tolerance vs. risk capacity
| Scenario | Better suitability instinct |
|---|---|
| Client says they want aggressive growth but cannot afford loss | Risk capacity limits the recommendation |
| Client can afford risk but is emotionally uncomfortable with volatility | Risk tolerance limits the recommendation |
| Client wants high income with no risk | Explain trade-offs; do not imply risk-free yield |
| Client wants liquidity but buys illiquid securities | Reassess objective and explain liquidity risk |
| Client has concentrated employer stock | Consider diversification and insider/trading restrictions |
KYP: what you must understand before recommending
| Product feature | Why it matters |
|---|---|
| Structure | Debt, equity, fund, derivative, structured note, exempt product, managed product |
| Return drivers | Interest rates, credit, equity markets, commodities, volatility, currency, leverage |
| Downside risk | Market loss, credit loss, liquidity loss, early redemption limits, complexity |
| Costs | Commissions, spreads, embedded fees, management fees, performance fees, penalties |
| Liquidity | Exchange-traded, redeemable, lock-up, secondary market limitations |
| Conflicts | Proprietary product, referral fee, underwriting relationship, compensation incentive |
| Tax profile | Interest, dividends, capital gains, return of capital, registered-account fit |
| Complexity | Whether the client can understand the recommendation and its risks |
Suitability: exam decision points
Suitability is not a one-time paperwork exercise. It is a judgment that connects the client’s facts to the recommendation, order, strategy, account type, and portfolio.
| Trigger or situation | Suitability focus |
|---|---|
| New account | Is the account type, risk profile, and initial strategy appropriate? |
| Recommendation | Is the product or strategy suitable for this client? |
| Significant KYC change | Does the current portfolio still fit? |
| New product or strategy | Does the representative understand it and is it approved for the client? |
| Concentrated position | Is the overall portfolio too exposed to one risk? |
| Leverage or margin | Can the client understand and withstand amplified losses? |
| Unsolicited order | Is there a need to warn, document, or escalate if the order appears unsuitable? |
| Account review | Are objectives, risk profile, and holdings still aligned? |
Suitability Traps Candidates Miss
| Trap | Why it is wrong |
|---|---|
| “The client signed the form, so it is suitable.” | Documentation supports suitability; it does not replace suitability. |
| “The product is low risk, so it suits everyone.” | Time horizon, liquidity, concentration, and objective still matter. |
| “The client is wealthy, so complex products are fine.” | Wealth is not the same as knowledge, tolerance, or need. |
| “The client requested the trade, so there is no duty.” | Unsolicited orders still require proper handling and documentation. |
| “High return objective means high-risk recommendation is suitable.” | Risk tolerance and risk capacity must support the objective. |
| “Diversification is only about number of holdings.” | Sector, issuer, geography, currency, and strategy concentration also matter. |
| “Disclosure cures all conflicts.” | Some conflicts must be avoided or controlled; disclosure may be insufficient. |
| “A good outcome proves the recommendation was suitable.” | Suitability is assessed based on information and process at the time. |
Account Types and Trading Authority
Account authority distinctions
| Concept | What it means | CPH trap |
|---|---|---|
| Non-discretionary account | Client makes investment decisions and gives specific instructions | Representative cannot decide key trade terms without authority |
| Trading authorization | Someone is authorized to place orders for the client | Authorization to place orders is not automatically full discretion |
| Power of attorney | Legal authority granted by the client, often broader than trading instructions | Must be valid, documented, and accepted under firm procedures |
| Discretionary account | Approved arrangement where an authorized person can make investment decisions | Requires proper authorization, supervision, and account approval |
| Managed account | Portfolio managed under a documented mandate | Do not treat ordinary advisory accounts as managed accounts |
| Time / price discretion | Limited discretion over execution timing or price after client gives key instructions | Do not confuse with selecting security, quantity, or buy/sell decision |
Account opening red flags
| Red flag | Why it matters |
|---|---|
| Third party gives all instructions | Possible unauthorized trading, undue influence, or beneficial ownership issue |
| Client does not understand account purpose | KYC and informed consent concern |
| Frequent address or banking changes | Fraud, identity, or AML concern |
| Client refuses to provide basic information | Account approval and AML issue |
| Elderly or vulnerable client suddenly changes strategy | Capacity, undue influence, or exploitation concern |
| Corporate account lacks authority documents | Instructions may not be legally valid |
| Client insists on secrecy | AML, tax, fraud, or misconduct concern |
Discretionary Trading and Managed Accounts
Discretion is a favorite CPH topic because the facts often look harmless: “The client was unavailable,” “the representative knew what the client wanted,” or “the market was moving quickly.” The exam usually wants formal authority, not convenience.
What makes a trade discretionary?
A trade may be discretionary if the representative chooses one or more essential elements without proper client instruction, such as:
- security or product;
- buy versus sell;
- quantity;
- account;
- timing beyond permitted limited discretion;
- price beyond permitted limited discretion;
- strategy or allocation.
Safer exam approach
| Situation | Better answer |
|---|---|
| Client says “do whatever you think is best” in a regular account | Obtain proper authority or specific instructions before trading |
| Client gave general objective but no trade details | Do not treat objective as an order |
| Client cannot be reached and market is moving | Follow firm procedures; do not create unauthorized discretion |
| Client previously bought similar securities | Past behavior does not authorize a new trade |
| Representative believes trade will help client | Good intention does not cure unauthorized trading |
Conflicts of Interest
Conflict analysis sequence
Use this sequence in CPH scenarios:
- Identify the conflict or potential conflict.
- Assess whether it is material.
- Avoid the conflict if it cannot be properly addressed.
- Control the conflict through supervision, restrictions, or process.
- Disclose clearly and in a timely way where appropriate.
- Document the analysis and action taken.
Common conflicts
| Conflict | Example | Exam-safe response |
|---|---|---|
| Compensation conflict | Higher commission product recommended over lower-cost alternative | Consider client’s interest, costs, suitability, and disclosure |
| Proprietary product | Firm product recommended when similar third-party options exist | Address conflict and suitability; avoid implying independence if limited |
| Referral arrangement | Client referred for compensation | Disclose relationship and follow firm rules |
| Outside activity | Representative has business interest outside the dealer | Obtain approval and manage client confusion/conflict |
| Gifts and entertainment | Incentive from issuer, product provider, or client | Avoid influence or appearance of influence |
| Personal financial dealings | Borrowing from or lending to a client | High-risk conflict; follow firm prohibitions and escalation rules |
| Family / close relationship | Representative handles account for related person | Disclose, supervise, and manage preferential treatment risk |
| Underwriting relationship | Firm promotes securities of issuer it is financing | Ensure appropriate disclosure and suitability review |
| Research / banking pressure | Recommendation influenced by investment banking relationship | Maintain independence and information barriers |
Client’s Interest and Standard of Conduct
CPH scenarios often test whether the registrant puts the client’s interest ahead of personal convenience, compensation, or firm pressure.
| Weak answer | Stronger answer |
|---|---|
| “The product pays more but is still allowed.” | Compare suitability, costs, alternatives, and conflicts. |
| “The client did not ask about fees.” | Explain material costs and compensation where required. |
| “The client is responsible for reading all documents.” | Provide clear, balanced explanation; documents do not excuse misleading conduct. |
| “Everyone in the branch sells this product.” | Suitability is client-specific. |
| “The firm approved the product, so it is suitable.” | Product approval is not client suitability. |
Communications, Advertising, and Social Media
High-yield communication rules
| Communication issue | What to remember |
|---|---|
| Fair and balanced | Include material risks, limitations, and assumptions |
| Not misleading | Avoid omissions, exaggeration, selective facts, or confusing comparisons |
| No guarantees | Do not imply guaranteed returns unless the guarantee is real, explained, and backed by an appropriate party |
| Performance claims | Avoid cherry-picking; disclose assumptions, periods, benchmarks, and limitations |
| Titles and designations | Use only accurate, approved titles; avoid implying expertise not held |
| Testimonials / endorsements | Follow firm approval and regulatory requirements |
| Social media | Business communications are still supervised communications |
| Email / messaging | Use approved channels and preserve records |
| Educational content | Can still be misleading if it promotes a product without balanced disclosure |
Communication traps
| Trap | Why it matters |
|---|---|
| “This is not a recommendation, just information.” | Context can make it a recommendation. |
| “Private message means no supervision.” | Business communications must be retained and supervised as required. |
| “Past performance speaks for itself.” | Past performance can mislead without context and risk disclosure. |
| “Low volatility means no risk.” | Credit, liquidity, inflation, concentration, and issuer risk may remain. |
| “Guaranteed income” | Income stream, principal protection, and issuer guarantee are different concepts. |
Trading Conduct and Market Integrity
Core trading obligations
| Area | Review point |
|---|---|
| Order instructions | Confirm account, security, action, quantity, order type, price limits, and timing |
| Order priority | Handle client orders fairly and according to priority rules |
| Best execution | Seek advantageous execution terms reasonably available under the circumstances |
| Fair allocation | Allocate fills fairly, especially for block or partial fills |
| Error handling | Report, correct, and document errors under firm procedures |
| Personal trading | Avoid front-running, conflicts, and misuse of client or firm information |
| Market manipulation | Do not create false or misleading market activity |
| Records | Maintain accurate order tickets, timestamps, communications, and approvals |
Prohibited or high-risk market conduct
| Conduct | Why it is a problem |
|---|---|
| Front-running | Trading ahead of client or firm orders using knowledge of those orders |
| Insider trading | Trading with material non-public information |
| Tipping | Sharing material non-public information with others |
| Wash trading | Trades with no real change in beneficial ownership to create false activity |
| Matched orders | Coordinated trades designed to mislead the market |
| Spoofing / layering | Orders intended to mislead rather than execute genuinely |
| Rumour-based trading | Acting on unverified or confidential information can harm market integrity |
| Manipulative marking-the-close activity | Trades designed to affect closing prices artificially |
Insider Trading and Material Non-Public Information
Test yourself: is the information risky?
| Question | If yes, be careful |
|---|---|
| Is the information about a public issuer or security? | It may affect trading decisions |
| Is it material? | A reasonable investor might consider it important |
| Is it non-public? | It has not been broadly disclosed |
| Did it come from a special relationship, client, issuer, insider, or confidential source? | Confidentiality and trading restrictions may apply |
| Would trading appear unfair to the market? | Market integrity concern |
Exam-safe response
If a representative receives possible material non-public information:
- Do not trade for self, client, or related accounts.
- Do not recommend trading based on the information.
- Do not tip others.
- Preserve confidentiality.
- Escalate to compliance or supervision.
- Follow information barrier procedures if applicable.
Complaints, Errors, and Misconduct
Recognizing a complaint
A complaint does not need magic words. If a client alleges unfair treatment, loss due to advice, unauthorized trading, misrepresentation, fee issues, service failure, or misconduct, treat it seriously.
| Scenario | Better CPH response |
|---|---|
| Client says “you never explained the risk” | Escalate and document as a potential complaint |
| Client demands reimbursement | Do not personally settle; notify supervisor/compliance |
| Representative made an order entry error | Report promptly under firm procedures |
| Client threatens regulator or lawyer | Escalate; do not argue or destroy records |
| Complaint seems unreasonable | Still follow complaint-handling process |
| Representative wants to call client privately to “fix it” | Communicate through approved process and document |
Complaint-handling traps
| Trap | Why it is wrong |
|---|---|
| Waiting to see if the client calms down | Delay can breach firm procedures and worsen harm |
| Paying the client personally | Creates conflict and may hide misconduct |
| Changing notes after the fact | Record integrity issue |
| Blaming the market | Complaint may be about process, disclosure, or suitability |
| Promising compensation | Unauthorized settlement risk |
| Ignoring oral complaints | Oral concerns can still require escalation |
AML, ATF, Sanctions, and Suspicious Activity
CPH candidates should understand the conduct logic: securities firms must know who they are dealing with, understand suspicious activity, and escalate through appropriate reporting channels.
Common red flags
| Red flag | Possible concern |
|---|---|
| Client reluctant to provide identification | Identity or beneficial ownership concern |
| Funds from unrelated third party | Source of funds or beneficial ownership concern |
| Transactions inconsistent with profile | Suspicious activity |
| Rapid in-and-out movement of funds | Layering or money movement concern |
| Client unconcerned with investment return | Money laundering concern |
| Use of multiple accounts without clear purpose | Structuring or concealment concern |
| Unusual foreign transfers | Sanctions, AML, or source of funds issue |
| Client asks how to avoid reporting | Evasion concern |
| Corporate structure is opaque | Beneficial ownership concern |
Exam-safe AML response
- Do not ignore red flags because the client is profitable.
- Do not warn the client inappropriately about internal reporting.
- Gather required information through approved processes.
- Escalate to the firm’s AML/compliance function.
- Keep records and follow firm procedures.
Privacy, Confidentiality, and Cybersecurity
| Issue | Review point |
|---|---|
| Client information | Collect, use, share, and retain only for proper business and regulatory purposes |
| Consent | Use client information consistently with consent and legal requirements |
| Confidentiality | Do not discuss client accounts with unauthorized third parties |
| Secure communication | Use approved systems and protect sensitive information |
| Cyber incidents | Escalate suspected compromise promptly |
| Internal access | “Need to know” matters; curiosity is not a business reason |
| Third-party requests | Verify authority before releasing information |
Vulnerable Clients, Trusted Contacts, and Undue Influence
CPH scenarios may include elderly clients, cognitive decline, unusual withdrawals, a new friend or relative giving instructions, or sudden changes to beneficiaries, risk profile, or strategy.
| Warning sign | Better response |
|---|---|
| Client seems confused about recent trades | Pause, clarify, document, and escalate |
| New third party dominates meetings | Confirm client wishes privately if appropriate and follow procedures |
| Sudden large withdrawal inconsistent with profile | Ask reasonable questions and escalate concerns |
| Client changes long-standing conservative strategy abruptly | Update KYC and assess suitability carefully |
| Suspected financial exploitation | Follow firm procedures for escalation and protective steps |
| Client refuses help but appears capable | Respect autonomy while documenting and escalating concerns as required |
Key trap: do not assume age alone means incapacity. Focus on facts, behaviour, authority, and firm procedures.
Fees, Costs, and Compensation
What candidates should review
| Cost or compensation item | Why it matters |
|---|---|
| Commissions | Affect recommendation conflicts and client return |
| Fee-based accounts | Must make sense for expected services and trading pattern |
| Embedded fees | Client may not see them directly but they affect return |
| Spreads | Relevant in fixed income and certain principal transactions |
| Deferred or redemption charges | Affect liquidity and suitability |
| Performance fees | Create incentive conflicts |
| Referral fees | Require conflict analysis and disclosure |
| Margin interest | Can materially affect leveraged strategies |
Fee-based account trap
A fee-based account is not automatically better or worse. It depends on:
- client needs;
- account size;
- expected trading frequency;
- services provided;
- costs compared with alternatives;
- conflict disclosure;
- ongoing suitability.
If a buy-and-hold client pays a recurring fee but receives little ongoing service, the account may raise suitability and fairness concerns.
Leverage, Margin, Short Selling, and Complex Strategies
Leverage decision rule
Leverage magnifies both gains and losses. In CPH scenarios, leverage requires stronger KYC, clearer risk disclosure, and careful suitability analysis.
| Strategy | Conduct concern |
|---|---|
| Margin borrowing | Losses can exceed initial cash invested; interest costs matter |
| Borrowing to invest | Client must have risk capacity and cash flow to service debt |
| Short selling | Potentially large losses, borrowing costs, recall risk, market risk |
| Options / derivatives | Complexity, expiry, leverage, assignment, volatility |
| Structured products | Payoff complexity, issuer credit risk, liquidity, costs |
| Inverse or leveraged funds | May be unsuitable for long-term holding if structure creates path dependency |
| Illiquid exempt products | Valuation, resale limits, concentration, disclosure |
Common leverage mistakes
| Mistake | Better exam answer |
|---|---|
| Recommending leverage to meet an unrealistic return target | Revisit objectives and risk capacity |
| Using home equity or borrowed funds casually | Assess debt service, downside, and liquidity |
| Assuming sophisticated client means leverage is suitable | Still analyze purpose, risk, and capacity |
| Ignoring margin calls | Explain forced sale risk |
| Treating stop-loss orders as full protection | Stops may not execute at expected price |
New Issues, Underwriting, and Primary Market Conflicts
| Issue | Review point |
|---|---|
| New issue allocation | Must be fair and consistent with firm procedures |
| Selling group compensation | May create conflict requiring disclosure and supervision |
| Connected or related issuer | Client needs clear conflict information |
| Due diligence | Do not rely only on promotional materials |
| Suitability | New issue popularity does not make it suitable |
| Selling pressure | Do not recommend because allocation is available or firm wants distribution |
| Stabilization or market activity | Must comply with market integrity rules |
Research, Recommendations, and Information Barriers
| Topic | CPH review point |
|---|---|
| Research independence | Recommendations should not be improperly influenced by banking or issuer relationships |
| Conflicts in research | Disclose material conflicts where applicable |
| Information barriers | Prevent misuse of confidential information |
| Rumours | Do not present unverified rumours as fact |
| Selective disclosure | Avoid giving some clients material information unfairly |
| Model portfolios | Still require client-specific suitability if used for recommendations |
Supervision and Compliance
Who is responsible?
| Role | Responsibility |
|---|---|
| Representative | Know client, know product, recommend suitably, document, escalate |
| Supervisor / branch manager | Review activity, approve accounts, monitor exceptions, address issues |
| Compliance | Policies, surveillance, advice, investigations, regulatory liaison |
| Firm | Systems of supervision, training, records, complaint handling, culture |
| Senior management | Oversight, resources, control environment |
Supervision traps
| Trap | Why it is wrong |
|---|---|
| “Compliance approved the product, so I can sell it to anyone.” | Product shelf approval is not suitability. |
| “The supervisor was copied, so I have no responsibility.” | Individual obligations remain. |
| “No client complaint means no issue.” | Surveillance may identify unsuitable activity before a complaint. |
| “Experienced representatives need less documentation.” | Experience does not replace records. |
| “Verbal approval is enough.” | Follow required documentation and approval process. |
Records and Documentation
What good documentation proves
Good records show what was known, considered, disclosed, recommended, instructed, approved, and escalated.
| Record | Why it matters |
|---|---|
| KYC information | Basis for suitability |
| Client communications | Evidence of explanation and instructions |
| Order records | What was ordered, when, and by whom |
| Disclosure records | Costs, risks, conflicts, relationship terms |
| Notes of meetings/calls | Context for advice and client decisions |
| Supervisory approvals | Account, product, trade, and exception oversight |
| Complaint file | Fair and timely handling |
| Error reports | Correction process and accountability |
Documentation trap
Documentation should reflect reality. Backdating, altering notes, or creating after-the-fact justifications can be worse than weak documentation because it raises integrity and misconduct concerns.
Ethics Scenarios: Fast Answer Framework
When stuck, run this checklist:
- Who is the client?
- Who gave the instruction?
- Is the account approved for this activity?
- Is KYC current and complete?
- Does the representative understand the product?
- Is the recommendation suitable for the client and portfolio?
- Is there a conflict?
- Was disclosure clear, balanced, and timely?
- Is the communication approved and not misleading?
- Should the issue be escalated?
- What records are required?
- Would the action look fair to the client, firm, regulator, and market?
Common CPH Question Patterns
| Question pattern | What the exam is testing |
|---|---|
| “Client insists…” | Whether client preference overrides suitability or conduct duties |
| “Representative believes…” | Whether good intentions excuse missing authority or documentation |
| “Firm approved…” | Difference between product approval and client suitability |
| “Urgent market opportunity…” | Whether urgency excuses shortcuts |
| “Long-time client…” | Whether familiarity replaces current KYC |
| “Wealthy client…” | Whether wealth replaces risk analysis |
| “Unsolicited order…” | Whether documentation and warnings are required |
| “Private conversation…” | Whether business communication and complaints must be recorded |
| “Everyone knows…” | Whether rumour or non-public information can be used |
| “Small gift…” | Whether conflicts can arise from appearance, not just amount |
Rapid Review Tables by Topic
KYC / suitability quick table
| If you see… | Focus on… |
|---|---|
| Retired client | income needs, capital preservation, liquidity, risk capacity |
| Young high-income client | objectives, debt, horizon, actual risk tolerance |
| Business owner | liquidity, concentration, tax, succession, business risk |
| Insider / employee of issuer | trading restrictions and material information |
| New immigrant or non-resident facts | identity, tax, jurisdiction, documentation |
| Client with heavy sector exposure | concentration and diversification |
| Client wants “safe high yield” | credit risk, liquidity risk, unrealistic expectations |
| Client wants options | knowledge, approval, risk, strategy, margin |
| Client wants to borrow to invest | debt service, loss capacity, disclosure |
Conflict quick table
| If you see… | Ask… |
|---|---|
| Higher commission | Is recommendation influenced by compensation? |
| Referral | Was the referral arrangement disclosed and approved? |
| Outside business | Could clients confuse roles or rely on registration? |
| Gift or entertainment | Could it influence advice or appear improper? |
| Personal loan | Is there prohibited personal financial dealing? |
| Proprietary product | Were alternatives and conflicts considered? |
| Related issuer | Was relationship clearly disclosed? |
Communications quick table
| If you see… | Watch for… |
|---|---|
| “Guaranteed” | Is the guarantee real and properly explained? |
| “No risk” | Misrepresentation |
| “Best return” | Unsupported performance claim |
| “Limited time only” | Sales pressure and suitability shortcuts |
| Social media post | Approval, supervision, recordkeeping |
| Client seminar | Balanced presentation and approved materials |
| New designation | Accuracy and approval of title |
| Performance chart | Benchmark, time period, assumptions, cherry-picking |
Mini Scenario Practice
Use these as quick self-tests before doing original practice questions.
Scenario 1: The rushed trade
A long-time client leaves a voicemail: “Buy more of that same tech stock if it dips today.” The client does not specify quantity or price.
Best instinct: clarify instructions before trading. Past holdings and general interest do not automatically provide full trade authority.
Scenario 2: The wealthy client
A wealthy entrepreneur wants to place most liquid assets into a private illiquid investment. They say they understand business risk.
Best instinct: assess liquidity needs, concentration, time horizon, knowledge, risk capacity, documentation, product approval, and conflicts. Wealth alone is not suitability.
Scenario 3: The friendly settlement
A representative made an error and wants to personally reimburse the client to avoid a complaint.
Best instinct: report the error and complaint concern through firm procedures. Do not privately settle or hide the issue.
Scenario 4: The hot tip
A client who works at a public company hints that earnings will be much better than expected and asks the representative to buy shares immediately.
Best instinct: do not trade or recommend; treat as possible material non-public information and escalate.
Scenario 5: The social media post
A representative posts, “Our income strategy is ideal for retirees who need safe monthly cash flow.”
Best instinct: likely misleading and unbalanced. Review approval, risk disclosure, suitability, and prohibited guarantee implications.
Last-Week Review Plan
| Day | Review focus | Practice task |
|---|---|---|
| Day 1 | KYC, KYP, suitability | Topic drills on client profiles and recommendations |
| Day 2 | Conflicts, fees, compensation | Scenario questions with disclosure/control decisions |
| Day 3 | Account authority, discretionary trading, managed accounts | Drills on who can give instructions and when |
| Day 4 | Trading conduct, insider information, market manipulation | Mixed market-integrity questions |
| Day 5 | Communications, complaints, privacy, AML | Compliance-process drills |
| Day 6 | Supervision, records, ethics | Case-based questions with escalation choices |
| Day 7 | Mixed mock exam review | Analyze explanations and redo missed topics |
How to Use a Question Bank After This Review
After reading this Quick Review, move into independent companion practice. CPH preparation improves fastest when you practice judgment under exam-style wording.
Best practice sequence
Start with topic drills
Drill KYC/suitability, conflicts, account authority, trading conduct, communications, complaints, and AML separately.Read detailed explanations carefully
Do not only mark right or wrong. Identify why the tempting answer was weaker.Build a trap log
Track errors such as “ignored conflict,” “assumed client consent was enough,” or “missed escalation.”Move to mixed sets
Mixed questions force you to identify the topic before choosing the rule.Finish with mock exams
Use mock exams to improve pacing, stamina, and scenario recognition.
Final Quick Review Checklist
Before your next practice set, confirm you can answer these without notes:
- What is the difference between KYC, KYP, and suitability?
- When does an order become discretionary?
- Why does an unsolicited order still create conduct obligations?
- What client facts matter most for risk capacity?
- What product facts matter most for KYP?
- When is disclosure not enough to handle a conflict?
- What should a representative do with possible material non-public information?
- How should complaints and errors be handled?
- What makes marketing communication misleading?
- What AML red flags require escalation?
- Why do records matter in suitability and complaint scenarios?
- What answer best protects the client, firm, and market?
Practical Next Step
Use this CPH Quick Review to identify weak areas, then work through original practice questions by topic. Focus on the detailed explanations for every missed or guessed question, especially scenarios involving suitability, conflicts, discretionary authority, complaints, and market integrity.