hard · CFA Level I ethics

A portfolio manager at Westfork Bancorp, Leo Thorne, is considering a significant investment in Pinion Logistics. He discovers on an anonymous social media forum a post from a user claiming to be a Pinion employee, alleging that the company’s internal shipping volumes are 15% higher than reported. Thorne also observes unusual weekend activity at Pinion's main terminal while driving by. He synthesizes this with a public report from Solstice Utilities showing a spike in industrial electricity demand in Pinion's region. Thorne immediately purchases shares for his clients. If Thorne had instead received a leaked, unannounced quarterly earnings draft from a Pinion executive, his purchase would be:

  1. A violation of Standard II(A) regardless of his other research.
  2. Permissible if he documented the mosaic before receiving the draft.
  3. Permissible if the earnings draft merely confirmed his existing mosaic.

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