You are reading the 2026 curriculum (exams up to November 2026). Sitting in February 2027 or later? Go to the 2027 Ethical and Professional Standards guide.
Standard IV(C): Responsibilities of Supervisors
Make reasonable efforts to ensure that everyone under your supervision or authority complies with laws, rules, regulations and the Code and Standards. That means an adequate compliance system, training, and prompt action on a suspected violation. If the system is inadequate, decline supervisory responsibility in writing until it is fixed.
Before this: Standard IV(B): Additional Compensation Arrangements
On the exam
- Demonstrate the application of the Code of Ethics and Standards of Professional Conduct to situations involving issues of professional integrity
- Recommend practices and procedures designed to prevent violations of the Code of Ethics and Standards of Professional Conduct
- Identify conduct that conforms to the Code and Standards and conduct that violates the Code and Standards
Demonstrate IV(C), recommend procedures and identify compliant conduct. Expect "what should the supervisor do on learning of a violation?" and "is the compliance system adequate?". The usual wrong answers are a warning alone, or resigning instead of declining in writing.
How deeply to learn each part
- Know the idea
- Understand it in general. It frames other topics, but you will not calculate with it.
- Use it
- Understand it well enough to solve a question with it. Recognize when it applies.
- Memorize
- Learn it by heart. The exam will not give it to you.
You know this one. The full lesson is folded away. The takeaways, formulas and checkpoint below are your quick refresher, and the checkpoint is a fair test of whether you still do.
You tested strong here. The full lesson is folded away. The takeaways, formulas and checkpoint below are your quick refresher, and the checkpoint is a fair test of whether you still know it.
Who is a supervisor, and what must they do?
Anyone with employees under their control or influence is a supervisor for this Standard, whether or not those employees are CFA Institute members, charterholders or candidates. You must make reasonable efforts to ensure that everyone under your supervision or authority complies with applicable laws, rules, regulations, firm policies and the Code and Standards. Supervisors also need in-depth knowledge of the Code and Standards.
Memorize
What is reasonable depends on how many people you oversee and what they do. A supervisor with a very large team may delegate day-to-day supervision to subordinates. The duty then includes teaching those subordinates how to prevent and detect violations.
At a minimum, the Standard requires reasonable efforts to prevent and detect violations by making sure an effective compliance system exists. That goes beyond writing a code of ethics and policies. Recurring education and incentives that reward ethical behavior, not only results, are part of an effective system.
- Build the system Memorize before any violation
- Adequate compliance procedures written, tailored, easy to follow
- Designated compliance officer clear authority and resources
- Training and incentives reward ethical behavior
-
- Detect Memorize
- Monitor and review check procedures are followed
-
- Respond to a violation Memorize
- Respond promptly and investigate do not rely on assurances
- Restrict or monitor the employee pending the outcome
- Review procedures prevent a repeat
-
- System inadequate Memorize you cannot supervise
- Tell senior management and recommend fixes
- Decline supervision in writing until reasonable procedures are adopted
-
What makes a compliance system adequate?
Adequate compliance procedures are designed to meet industry standards, regulatory requirements, the Code and Standards and the firm’s circumstances. They must exist before a violation occurs. They cannot predict every breach, but they should anticipate the activities most likely to cause one. Adequate procedures:
- sit in a clearly written, accessible manual tailored to the firm’s operations;
- are easy to understand;
- designate a compliance officer with clear authority, responsibility and resources;
- describe the hierarchy of supervision and who does what;
- build in checks and balances;
- document how compliance is monitored and tested;
- set out permissible conduct, and how violations are reported and sanctioned.
Once the program is in place, disseminate it, update it, remind people of it, include conduct in performance reviews and enforce it. A supervisor with no power over firm-wide policy should still work through the firm’s structure to improve them.
A code of ethics and compliance procedures are different things. The code states plain-language principles for everyone, and the procedures turn them into daily practice. Keeping them separate helps the code stay readable and stresses ethical culture over rule-following.
How does a supervisor detect violations?
Detection is part of supervision. You exercise reasonable supervision by putting written procedures in place and checking through periodic review that they are followed. If you adopted reasonable procedures and a determined employee still evades them undetected, you may not have violated IV(C). But violations that do occur can signal that the procedures are inadequate. You may also be in breach if you know or should know that the procedures are not being followed.
What if a violation is suspected?
Once you learn that an employee has or may have violated the law or the Code and Standards, you must promptly start an assessment of the extent of the wrongdoing. The recommended steps are to:
- respond promptly;
- conduct a thorough investigation of the scope of the wrongdoing;
- increase supervision or limit the employee’s activities pending the outcome;
- review the procedures for changes that would prevent a repeat.
The following are not enough on their own: relying on the employee’s statements or promises, warning the employee to stop, or reporting the matter up the chain of command.
What if the system is inadequate?
Bring the problem to senior management and recommend corrective action. If the absence or weakness of a compliance system clearly means you cannot discharge your duty, the Standard says to decline in writing to accept supervisory responsibility until the firm adopts reasonable procedures. This declining supervisory responsibility is the remedy. It does not mean resigning, and it is not accepting the role and hoping to fix things.
Where do the lines fall?
| Situation | Verdict |
|---|---|
| A desk head learns a trader may be front-running client orders and only reminds him of the policy | Violation (must investigate and restrict) |
| A new head of research finds no policy on personal trading, documents the gap and declines supervisory duty in writing until one is adopted | Consistent with IV(C) |
| A supervisor relies on a well-designed system that a determined employee evades despite monitoring | Not a violation by the supervisor (reasonable efforts) |
| A chief investment officer (CIO) delegates supervision but never checks whether the delegate follows up on exceptions | Likely violation: delegating does not end the duty, and a supervisor who should know procedures are not followed is in breach |
Try this 0 of 3
- Reject the wrong responses and order the response first time
- Choose to decline supervision in writing, first time
- Spot the supervisor who did not violate IV(C)
Case 1 of 4 The alarm
Grace Lindholm, CFA, heads the equity trading desk at Pelham Street Asset Management. On Monday the firm's surveillance report flags that a trader on her desk, Owen Pryce, bought shares in his personal account minutes before large client orders in the same stocks, three times in two weeks. Owen says it is a coincidence. Grace has not yet done anything about the report.
Step 1 of 4 Violation detected
Which response meets Grace's duty as his supervisor?
Read the case, then answer each step. 4 cases.
How should firms support supervisors?
Regular compliance training helps staff spot ethical and legal pitfalls and conditions that cloud judgment. It cannot stop someone set on fraud, but it builds a culture of integrity for the large majority who want to do the right thing. Incentives matter too. A “succeed at all costs” culture that rewards results regardless of method pushes people to cut corners. Supervisors and firms should check that pay structures do not encourage profit at the expense of ethical conduct.
Exam tip A supervisor’s answer to a suspected violation always has two parts: find out what happened, and stop it spreading while you do.
Go deeper Why the Standard covers non-members
Supervisors answer for the conduct of everyone under their authority, because clients are harmed by any employee’s misconduct, whether or not that person holds a credential. Applying the Code to all staff also stops firms treating ethics as a duty only for the few people who carry a designation. A supervisor who is a member must apply the Standards to the people they oversee.
Go deeper Culture and incentives
Written procedures can be followed to the letter in a firm whose real message is “win at any price”. Supervisors set that message through what they reward, promote and tolerate. That is why the recommended procedures include a professional conduct evaluation in performance reviews and incentive plans that recognize ethical behavior. A system that only looks for rule-breaking misses the supervisor’s biggest influence.
Memorize this
MemorizeStandard IV(C): what to know cold
| Point | The rule |
|---|---|
| Who is a supervisor | Anyone with employees under their control or influence, members or not |
| Duty | Reasonable efforts to prevent and detect violations through an effective compliance system |
| On a suspected violation | Act promptly, investigate the scope, restrict or monitor the employee meanwhile, review procedures |
| Not enough | A warning, the employee's assurances, or only reporting up the chain |
| Inadequate system | Tell senior management, recommend fixes, and decline supervision in writing until procedures are adopted |
| Liability | Not for every violation: a reasonable system that a determined employee evades is not the supervisor's breach |
Memory hook Prevent, detect, respond: a system before the problem, then investigate and restrict the moment something looks wrong.
Know it cold Reasonable efforts judged by the system and the response. A reminder is never a response.
- Build the system Memorize before any violation
- Adequate compliance procedures written, tailored, easy to follow
- Designated compliance officer clear authority and resources
- Training and incentives reward ethical behavior
-
- Detect Memorize
- Monitor and review check procedures are followed
-
- Respond to a violation Memorize
- Respond promptly and investigate do not rely on assurances
- Restrict or monitor the employee pending the outcome
- Review procedures prevent a repeat
-
- System inadequate Memorize you cannot supervise
- Tell senior management and recommend fixes
- Decline supervision in writing until reasonable procedures are adopted
-
How it is asked
-
Warning and nothing else
A trading head suspects front-running, reminds the trader of the policy and does nothing more. Violation?
Yes, IV(C). Investigate and restrict. Trap: VI(B) is the trader's breach, not hers.
-
No compliance procedures
A new director of research finds no adequate procedures. Best action?
Decline in writing to accept supervisory responsibility until adequate procedures exist. Trap: accept and fix it later.
-
Which is not part of an adequate system?
Compliance officer, regular training, or employees writing their own rules?
Employees writing their own rules.
Exam traps
- Treating a verbal reminder or warning as an adequate response to a suspected violation. Investigate and restrict.
- Thinking a supervisor is liable for every violation. Reasonable efforts with an adequate system is the test.
- Resigning as the remedy for an inadequate system. The Standard says to decline supervisory responsibility in writing until it is fixed.
- Confusing the two breaches. The employee's trading is a VI(B) issue, and the supervisor's failure to act is IV(C).
- Forgetting that supervision covers non-members too.
Checkpoint
3 exam-style questions. About 90 seconds each.
1A head of trading suspects a junior trader of trading ahead of client orders. She reminds the trader of the firm's policy and takes no other action. Did she violate the Standards?
2A newly appointed director of research finds that the firm has no adequate compliance procedures for research. The director's most appropriate action is to:
3Which is least likely to be part of an adequate compliance system?
Key takeaways
- Supervisors make reasonable efforts to prevent and detect violations through an adequate compliance system.
- On a suspected violation, investigate promptly and restrict or monitor the employee meanwhile.
- No adequate system? Decline supervisory responsibility in writing until there is one.
Questions about this lesson?
Where this comes back
- Standard V(A): Diligence and Reasonable Basis Guidance for Standards I–VII
Questions candidates ask
What are the responsibilities of supervisors under the CFA Standards?
Make reasonable efforts to prevent and detect violations by everyone under your supervision or authority. That means an adequate compliance system, regular training, monitoring, and a prompt investigation with restrictions when you learn of a possible violation.
What should a supervisor do when an employee violates a policy?
Respond promptly and investigate the scope of the wrongdoing. Pending the outcome, restrict or closely monitor the employee, then review the procedures. A warning, the employee's assurances, or reporting up the chain alone are not enough.
What if my firm's compliance system is inadequate?
Raise it with senior management and recommend corrective action. If you clearly cannot supervise without a proper system, decline supervisory responsibility in writing until reasonable procedures are adopted.
Spotted an error? Tell us and we will fix it.