Ethics — 2025 CFA Curriculum Updates

Overview

The CFA Institute periodically updates the Ethics and Professional Standards curriculum to reflect evolving market practices, regulatory developments, and enforcement trends. The 2025 updates addressed several areas where prior guidance was insufficient or where candidate confusion was common. These updates are testable on the Level III exam.

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Key 2025 Updates

1. Standard VI(A) — Disclosure of Conflicts: Social Media and Third-Party Content

The 2025 curriculum clarified that disclosure obligations under Standard VI(A) extend to conflicts arising from social media endorsements, sponsored content, and third-party referral arrangements. If a member receives compensation (monetary or non-monetary, including gifts, access, or preferential treatment) for recommending a product, firm, or service through any channel — including personal social media accounts — that compensation must be disclosed.

Exam implication: A member who posts favorable commentary about a fund manager on LinkedIn without disclosing a referral fee arrangement violates Standard VI(A) regardless of whether the post appears personal rather than professional.

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2. Standard I(D) — Misconduct: Expanded Definition of Relevant Personal Conduct

The 2025 update clarified that misconduct under Standard I(D) now explicitly addresses personal conduct that is directly relevant to professional trustworthiness, including:

• Misrepresentation on professional credential applications
• Falsification of continuing education records
• Material dishonesty in regulatory filings even when not subject to a client relationship

The prior curriculum left ambiguity about whether purely personal misconduct (outside of client-facing activity) could trigger Standard I(D). The 2025 version removes that ambiguity: any conduct reflecting on the member's honesty, integrity, or fitness to practice is in scope.

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3. Asset Manager Code — Integration with Standard III(C) Suitability

The 2025 curriculum strengthened the connection between the Asset Manager Code and Standard III(C). Specifically, the update emphasized that institutional managers cannot treat a mandate's investment policy statement (IPS) as a substitute for ongoing suitability review. If a client's circumstances change materially (liquidity need, tax status, time horizon), the manager must proactively reassess — not wait for the client to raise it.

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4. GIPS 2020 Alignment — Composite Definition Precision

The 2025 curriculum reinforced that composite definitions must be prospective and mechanical — meaning the rules for including a portfolio in a composite must be set before the performance period, not retroactively selected based on performance. Retroactive exclusion of poor-performing portfolios from a composite is a GIPS violation and a Standard III(D) misrepresentation issue.

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Exam Strategy for 2025 Ethics Updates

• The exam will test application, not memorization of the update text. Expect scenario-based questions where a member's conduct is described and you must identify which standard (if any) was violated.
• When in doubt between two standards, ask: does the issue involve disclosure (VI(A)), accuracy of information (I(C)), client interest (III(A)), or honesty (I(D))? The answer usually points to the correct standard.
• The 2025 updates do not override prior standards — they clarify and extend them. All prior ethics rules remain fully applicable.