IACCP EXAM QUESTIONS AND CORRECT ANSWERS |2026/2027
UPDATED |GUARANTEED PASS.
MNVAW
Materiality
Nonpublic
Violation of duty & trust
Actions or trading
Wrongful intent ("scienter" - knowing or reckless - not just negligence) - Answer -Primary
Elements of Insider Trading (scope)
Place issuer on restricted trading list (otherwise, knowledge of MNPI can be attributed firm-
wide absent proof info was not passed within firm, which is nearly impossible to prove) -
Answer -Best practice if any employee came into possession of MNPI and why so?
Viewed as significant to trade decision-making.
Level of materiality is determined on sliding scale according to significance of data/event and
likelihood of occurrence (Info likely to move market once disclosed?) - Answer -What makes
nonpublic information materially NPI (MNPI)?
SUPERVISED: Partner, director, officer, or similar status, or employee of adviser, or other person
providing investment advice on behalf of adviser AND is subject to supervision/control of
adviser
ACCESS PERSON: Any supervised person having access to client NPI regarding client's securities
transactions or to NPI client recommendations - Answer -Define Supervised vs Access Person
1|Page
,SPRA
Standards of conduct
Pre-clearance obligations
Reporting obligations
Access to the code - Answer -What are the required elements of a firm's Code of Ethics?
Direct obligations to US Gov, Banker's products (CDs, commercial paper, certain debt
instruments, etc.), Money-market funds, Open-end funds (MFs), Unit investment trusts invested
exclusively in 1 or more MFs (REITs);
Accounts over which access person has no direct or indirect control or influence;
Automatic investment plan transactions;
Duplicate reports otherwise contained in broker trade confirmations received by firm - Answer -
Holdings exempt from reportable securities include
Access persons: Reportable Securities in which access person has direct or indirect beneficial
ownership
ANNUAL HOLDINGS 10 calendar days of becoming access and annually thereafter with 45 days
year-end; and
QUARTERLY TRANSACTION details within 30 days quarter-end must report all transaction details
for - Answer -Who is required to report transactions per CoE and when?
Fiduciary duty, Compliance with federal securities laws, Reporting of violations and personal
securities holdings and transactions, acknowledgement of receipt of Code of Ethics - Answer -
What elements of the Code require employee's written acknowledgement?
2|Page
, Pre-Clearance required (typically by CCO) for IPOs and private placements - Answer -
Transactions related to what types of holdings does the Code mandate as requiring pre-
clearance?
None specifically required/mandated by the Rule/SEC. However, advisers often implement
additional firm-tailored procedures to include prohibitions on certain trading, black-out periods
on trading, restrictions on outside activities, accepting/giving of gifts/entertainment, charitable
contributions, and pay-to-play (political contribution) policies. - Answer -What are the Code
requirements as related to Blackout Periods and Restricted Lists?
None directly however, no-action relief (SMC Capital) permits, but does not require, aggregation
of client orders under certain circumstances. Additionally, orders involving proprietary accounts
are permitted when appropriate procedures are followed. - Answer -What is the SEC/Act's
stance on allocating client trade orders?
Combining orders of the same security for several clients into a single order
Pros: adviser can generally improve price, transaction costs, and other aspects of trade
execution
Cons: potential conflict of interest as not all clients may have purchased at same time for same
price - Answer -Define aggregation of client trade orders and the pros/cons
10 Conditions:
1) Disclose aggregation policies
2) Consistency with seeking best execution
3) Fair & equitable treatment
3|Page
UPDATED |GUARANTEED PASS.
MNVAW
Materiality
Nonpublic
Violation of duty & trust
Actions or trading
Wrongful intent ("scienter" - knowing or reckless - not just negligence) - Answer -Primary
Elements of Insider Trading (scope)
Place issuer on restricted trading list (otherwise, knowledge of MNPI can be attributed firm-
wide absent proof info was not passed within firm, which is nearly impossible to prove) -
Answer -Best practice if any employee came into possession of MNPI and why so?
Viewed as significant to trade decision-making.
Level of materiality is determined on sliding scale according to significance of data/event and
likelihood of occurrence (Info likely to move market once disclosed?) - Answer -What makes
nonpublic information materially NPI (MNPI)?
SUPERVISED: Partner, director, officer, or similar status, or employee of adviser, or other person
providing investment advice on behalf of adviser AND is subject to supervision/control of
adviser
ACCESS PERSON: Any supervised person having access to client NPI regarding client's securities
transactions or to NPI client recommendations - Answer -Define Supervised vs Access Person
1|Page
,SPRA
Standards of conduct
Pre-clearance obligations
Reporting obligations
Access to the code - Answer -What are the required elements of a firm's Code of Ethics?
Direct obligations to US Gov, Banker's products (CDs, commercial paper, certain debt
instruments, etc.), Money-market funds, Open-end funds (MFs), Unit investment trusts invested
exclusively in 1 or more MFs (REITs);
Accounts over which access person has no direct or indirect control or influence;
Automatic investment plan transactions;
Duplicate reports otherwise contained in broker trade confirmations received by firm - Answer -
Holdings exempt from reportable securities include
Access persons: Reportable Securities in which access person has direct or indirect beneficial
ownership
ANNUAL HOLDINGS 10 calendar days of becoming access and annually thereafter with 45 days
year-end; and
QUARTERLY TRANSACTION details within 30 days quarter-end must report all transaction details
for - Answer -Who is required to report transactions per CoE and when?
Fiduciary duty, Compliance with federal securities laws, Reporting of violations and personal
securities holdings and transactions, acknowledgement of receipt of Code of Ethics - Answer -
What elements of the Code require employee's written acknowledgement?
2|Page
, Pre-Clearance required (typically by CCO) for IPOs and private placements - Answer -
Transactions related to what types of holdings does the Code mandate as requiring pre-
clearance?
None specifically required/mandated by the Rule/SEC. However, advisers often implement
additional firm-tailored procedures to include prohibitions on certain trading, black-out periods
on trading, restrictions on outside activities, accepting/giving of gifts/entertainment, charitable
contributions, and pay-to-play (political contribution) policies. - Answer -What are the Code
requirements as related to Blackout Periods and Restricted Lists?
None directly however, no-action relief (SMC Capital) permits, but does not require, aggregation
of client orders under certain circumstances. Additionally, orders involving proprietary accounts
are permitted when appropriate procedures are followed. - Answer -What is the SEC/Act's
stance on allocating client trade orders?
Combining orders of the same security for several clients into a single order
Pros: adviser can generally improve price, transaction costs, and other aspects of trade
execution
Cons: potential conflict of interest as not all clients may have purchased at same time for same
price - Answer -Define aggregation of client trade orders and the pros/cons
10 Conditions:
1) Disclose aggregation policies
2) Consistency with seeking best execution
3) Fair & equitable treatment
3|Page
