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CFA > CFA L2 Ethics > Flashcards

CFA L2 Ethics Flashcards

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1
Q

Ethical conduct

A

Behavior that follows moral principles and is consistent with society’s ethical expectations. It is also conduct that improves outcomes for stakeholders.

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2
Q

Code of ethics

A

A written set of moral principles provided to the public that can guide behavior by describing what is considered acceptable behavior. Some codes of ethics include a set of rules or standards that require some minimum level of ethical behavior.

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3
Q

Profession

A

Occupational groups that require some level of required knowledge and must agree to abide by a common code of ethics. A profession IS NOT the same as an occupation

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4
Q

Profesional code of ethics

A

A way for a profession to communicate to the public that its members will use their knowledge and skills to serve their clients in an honest and ethical manner, and can increase public confidence and trust that members will act ethically.

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5
Q

Problems with a lack of ethical standards in investment management

A

Trust is critical and w/o it, people will not give you their money. This will end up increasing the cost of capital. A lack of standards also has a broader negative effect on the economy as a whole.

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6
Q

Suitability standard

A

A standard that requires that the investment recommendations given by investment professionals match up w/ the client’s risk/return requirements. When Members and Candidates are responsible for managing a portfolio to a specific mandate, strategy, or style, they must make only investment recommendations or take only investment actions that are consistent with the stated objectives and constraints of the portfolio.

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7
Q

Fiduciary standard

A

A standard that requires investment professionals to use their knowledge and expertise to act in the best interests of the client.

  • This is a higher standard than suitability
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8
Q

Challenges to ethical behavior

A
  • overestimating one’s own ethical character
  • considering only near-term consequences and not longer-term consequences of behavior
  • letting situational influences/ external influences unduly affect one’s decisions and behavior.
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9
Q

True or false: Not all unethical activities are illegal and not all illegal actions are unethical?

A

TRUE

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10
Q

Ethical decision-making framework

A
  • Identify: facts, stakeholders, ethics, and conflicts
  • Consider: situational influences, guidance from outside sources, alternative actions
  • Decide and act
  • Reflect: Was the outcome as anticipated?
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11
Q

Common situational influences

A
  • Social pressure
  • Loyalty to employer
  • Money, power, or prestige
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12
Q

True or false: Ethics tend to be more specific than laws/regulations and laws require more judgement

A

False, laws tend to be more specific than ethics but ethics require more judgement.

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13
Q

Circumstances that can prompt a CFA Professional Conduct Program inquiry

A
  • Self admission
  • Written complaints
  • Evidence of misconduct through a public source
  • Report by a CFA exam proctor
  • Analysis of exam score/materials and monitoring of social media by CFA Institute.
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14
Q

Process for the enforcement of the CFA Code and Standards

A
  • Begin an inquiry
  • interview the subject and whoever made the inquiry.
  • The CFA will decide
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15
Q

Disciplinary Review Committee

A

A department of the CFA Board of Governors. This committee DOES NOT look at inquiries. The Professional Conduct Program Staff looks at inquiries.

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16
Q

Types of decisions issued by Disciplinary Review Committee

A
  • No disciplinary action is needed
  • Cautionary letter
  • Discipline (this could be a # of things. The worst being kicked out of the program)
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17
Q

What are the six components of the Code of Ethics

A
  • Act in an ethical manner that displays integrity, competence, and respect.
  • Integrity is paramount and the client’s interest always comes first.
  • Use reasonable care & use independent judgement when working.
  • Practice and encourage others to act in an ethical way that will reflect credit on members and their profession.
  • Promote the integrity and viability of the global capital markets for the benefit of society.
  • Maintain and improve professional competence and professional competence of others.
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18
Q

What are the seven Standards of Professional Conduct?

A
  1. Professionalism
  2. Integrity of capital markets
  3. Duties to clients
  4. Duties to employers
  5. Investment analysis, recommendations, and actions
  6. Conflicts of interest
  7. Responsibilities as a CFA Institute Member or CFA Candidate
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19
Q

Standard 1: Professionalism

A
  • Knowledge of the law
  • Independence/objectivity
  • Misrepresentation
  • Misconduct
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20
Q

Standard I(A): Knowledge of the law

A

Maintain knowledge and don’t violate any laws, rules, or regulations that apply to your professional activities. This includes the CFA Code and Standards. The rule is that CFA members must always follow the strictest law possible. The Code and Standards DO NOT require that members report legal violations to the appropriate governmental or regulatory organizations, but such disclosure may be prudent in certain circumstances. If you cannot remove yourself from these violations, you must remove yourself from the firm. Members are responsible for activities in which they knowingly participate or assist. THIS IS ALL REQUIRED

  • The first step when discovering any violation is always to notify supervisor/compliance.
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21
Q

Knowledge of the law- RECOMMENDATIONS for CFA members

A
  • Keep informed about changes in law
  • Review firm’s written compliance procedures
  • Seek legal counsel when needed
  • When disassociating w/ bad activities, keep a record and encourage firms to stop
  • Report violations to government
  • Report violations of other CFA members

THESE ARE RECOMMENDED

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22
Q

Knowledge of the law- RECOMMENDATIONS for firms

A
  • Have a code of ethics
  • Provide employees w/ info on laws/regulations
  • Have procedures for reporting violations

THESE ARE RECOMMENDED

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23
Q

Standard I(B): Independence and objectivity

A

Members and Candidates must use reasonable care and judgment to achieve and maintain independence and objectivity. Do not be pressured by others to do anything biased towards one party. Do not accept bribes. Gifts from clients should be disclosed to employer before receiving WHEN POSSIBLE. Only accept modest gifts.

THESE ARE REQUIRED

  • Research analysts must strictly limit the types of issuer-paid research (when the company you are writing the report on pays for you to write the report). The preference is for a flat fee w/o compensation related to the conclusion of the report.
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24
Q

Independence and objectivity- RECOMMENDATIONS for CFA members

A

Members/ their firms should pay for their own travel to company events when possible, however the client can pay if the member remains objective. Also, limit the use of corporate aircraft to trips for which commercial travel is not an alternative or is inefficient.

THIS IS RECOMMENDED

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25
Q

Independence and objectivity- RECOMMENDATIONS for firms

A
  • Restrict employee participation in IPOs/private placements unless approval is given
  • Create a restricted list
  • Have a compliance officer
  • Limit gifts from non-clients to token items only.
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26
Q

Standard 1(C): Misrepresentation

A

Members must not knowingly make any misrepresentations in professional activities. They must make diligent efforts to prove that third party material is reliable. Actions that violate this standard are:
* Presenting 3rd party research as your own unless the information is factual data from a recognized financial/ statistical reporting service.
* Guaranteeing a specific return on securities when you can’t.
* Selecting a valuation firm because it puts a high value.
* Selecting an unreasonable performance benchmark.
* Presenting data that omits relevant facts.
* Present misleading info about the firm or its history.
* Using 3rd party marketing materials that are misleading.

  • Even if using a reputable statistical source, a member should still cite the source if they use a combo of different statistical sources rather than just one.
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27
Q

Misrepresentation- RECOMMENDATIONS for CFA members

A
  • Prepare a summary for clients of your experience and what you can do
  • Encourage employers to verify 3rd party marketing materials
  • Cite sources
  • Keep copies of materials used in research reports
  • Create a list of the firm’s qualifications and services
  • Periodically review your documents for any misrepresentation
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28
Q

Standard 1(D): Misconduct

A

Do not engage in any professional conduct involving dishonesty, fraud, or deceit or commit any act that reflects adversely on their professional reputation, integrity, or competence. Any act involving lying, cheating, or stealing is considered dishonest.

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29
Q

Misconduct- RECOMMENDATIONS for firms

A
  • Develop a code of ethics
  • Give employees a list of potential violations and sanctions, including dismissal.
  • Check the references of potential employees
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30
Q

Standard 2: Integrity of capital markets

A
  • Material nonpublic info
  • Market manipulation
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31
Q

Standard 2(A): Material nonpublic information

A

Do not act on impactful classified info that could affect the value of an investment. Information is material “if its disclosure would affect the price of a security or if a reasonable investor would want the information before making an investment decision”. The only people within your firm that you can share with are designated supervisor of compliance issues (who’s not necessarily YOUR supervisor).

THIS IS REQUIRED under Mosaic theory

  • Mosaic theory states that there is NO violation if an analyst reaches an investment conclusion about a corporate action through analysis of public information combined with NONMATERIAL nonpublic info. Ex: If you’re walking through a mall and see a large group of kids wanting to buy a certain clothing item and you rate that clothing item a buy, this is fine under the Mosaic Theory.
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32
Q

Material nonpublic information- RECOMMENDATIONS for CFA members

A
  • Encourage their firms to adopt procedures to prevent the misuse of material nonpublic information
  • Encourage the firm to disseminate info to the public
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33
Q

Material nonpublic information- RECOMMENDATIONS for firms

A
  • Create an information barrier to control communication between departments
  • Review employee trading
  • Maintain watch, restricted, and rumor lists
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34
Q

Standard 2(B): Market manipulation

A

Do not engage in practices that distort prices or distort trading volume w/ the intent to mislead market participants. Transaction-based manipulation includes, but is not limited to, transactions that artificially distort prices or volume. Information-based manipulation includes, but is not limited to, spreading false rumors about a firm in order to induce others to trade.

  • Sometimes prices/volume can get distorted by member actions but it is only considered a violation if the intent is to mislead
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35
Q

Standard 3: Duties to clients

A
  • Loyalty, prudence, and care
  • Fair dealing
  • Suitability
  • Performance Presentation
  • Preservation of confidentiality
36
Q

Standard 3(A): Loyalty, prudence, and care

A

CFA members must put their client’s interests before their own & must:
* Exercise prudence, care, skill, and diligence
* Manage pool of client assets in accordance w/ governance
* Make investment decisions that benefit the entire portfolio
* Vote proxies in an informed and responsible manner
* Inform clients of any limitations in an advisory relationship
* Client brokerage or ‘soft dollars’ must be used to benefit the client
* The client” may be the investing public as a whole rather than a specific entity or person.”

  • Brokerage commissions may NOT be used for a member’s operating expenses. They MUST be used for the benefit of the client.
  • Brokerage is an asset of the client.
  • Directed brokerage occurs when the client requests that a portion of the client’s brokerage be used to purchase services that directly benefit the client.
  • Tax liabilities of beneficiaries MUST be considered.
37
Q

Loyalty, prudence, and care- RECOMMENDATIONS for CFA members

A
  • Follow rules & laws
  • Establish client risk/return objectives
  • Diversify the portfolio
  • Deal fairly w/ clients
  • Keep client info confidential
  • Seek best trading execution for clients
  • Establish regular client meetings
38
Q

Standard 3(B): Fair dealing

A
  • Deal fairly and objectively with all clients.
  • Different service levels are acceptable, but they must not negatively affect any clients.
  • Disclose the different service levels to all clients/ prospects, and make premium levels of service available to all those willing to pay for them.
  • Treat clients fairly in light of their investment objectives and circumstances.
  • Treat both individual and institutional clients in a fair and impartial manner.
  • Members distributing IPO shares must distribute shares in an oversubscribed IPO to clients and may not withhold shares for themselves. If the issue is oversubscribed, then the issue is to be prorated to all subscribers

Fair ≠ equal

39
Q

Fair dealing- RECOMMENDATIONS for CFA members

A
  • Maintain a list of clients and holdings—use to ensure that all holders are treated fairly
  • Encourage firms to establish compliance procedures to treat all clients fairly
40
Q

Fair dealing- RECOMMENDATIONS for firms

A
  • Limit # of people aware of upcoming change
  • Shorten time frame between decision and dissemination
  • Have pre-decision guidelines
  • Simultaneous dissemination
  • Disclose trade allocation procedures
  • Review accounts regularly to ensure fair client treatment
  • Execute orders on FIFO basis
41
Q

Standard 3(C): Suitability

A

When a CFA member is in an advisory position they must take into account the client’s risk/return objectives and investing knowledge prior to making any investment decisions for them. Members should document unsuccessful attempts to update client information and circumstances. Things that must be considered when making an IPS:
* client identification
* investment objectives (risk/return)
* investment benchmark

42
Q

Suitability- RECOMMENDATIONS for CFA members

A
  • Make an IPS for each client
  • Review client’s IPS periodically
  • Update IPS at least annually
43
Q

What to do if client requests an investment that is unsuitable for their objectives?

A

The advisor should discuss w/ client why it is unsuitable. If the investment is not material and won’t affect the portfolio, follow firm’s guidelines on unsuitable investments. If it is material, update IPS. If they decline updating IPS, follow firm policies and possibly end relationship w/ client.

44
Q

Standard 3(D): Performance presentation

A

When communicating investment performance info, make reasonable efforts to ensure that it is fair, accurate, and complete. Do not misstate performance or mislead clients about their/ the firm’s investment performance. For brief presentations, members must make detailed information available on request and indicate that the presentation has offered only limited information.

  • The word reasonable has a high standard w/ CFA
  • Members are required to promptly disclose any changes in benchmarks used in performance presentation. Members should explain the reasons for changing the benchmark and present the performance reports using both the old and new methodologies so that clients may compare them.
  • Returns can be presented net of fees and/or gross of fees.
45
Q

Performance presentation- RECOMMENDATIONS for CFA members

A
  • Encourage firms to adhere to Global Investment Performance Standards.
  • Consider sophistication of audience
  • Present the performance of several accounts rather than just one
  • Include terminated accounts as part of historical performance and clearly state when they were terminated.
  • Include all appropriate disclosures to fully explain results
  • Maintain data and records used to calculate the performance being presented
46
Q

Standard 3(E): Preservation of confidentiality

A

Keep info about past, current, or prospective clients confidential unless disclosure of illegal activity, disclosure is required by law, or the client permits disclosure. The confidentiality standard applies to any information that a member has learned in the performance of his duties for the client. This standard also applies to former clients. Exception: It is allowed to provide confidential info to the CFA Institute under the Professional Conduct Program.

47
Q

Preservation of confidentiality- RECOMMENDATIONS for CFA members

A
  • Only disclose client info to authorized colleagues
  • Members should follow firm procedures for storage of electronic data and recommend adoption of such procedures if they are not in place.
48
Q

Standard 4: Duties to employers

A
  • Loyalty
  • Additional compensation arrangements
  • Responsibilities of a supervisor
49
Q

Standard 4(A): Loyalty

A

Act for the benefit of the employer. Do not engage in any activities that would injure the firm, deprive it of profit, or deprive it of the advantage of employees’ skills and abilities. Always place client interests above interests of employer, but consider the effects of actions on firm integrity and sustainability. Act in best interest of employer until resignation is effective. This standard DOES NOT have a blanket prohibition against independent practice in competition with a member’s employer. You just must have WRITTEN permission from employer, and inform them of types of service to be rendered, the expected duration, and the expected compensation. Employer records in any form are property of the firm.

  • A departing employee is “generally free to make arrangements or preparations to go into a competitive business before terminating the relationship with the employee’s employer provided that such preparations do not breach the employee’s duty of loyalty”.
50
Q

Loyalty- RECOMMENDATIONS for CFA members

A
  • Give employer copy of CFA Code & Standards
  • Use separate social media accounts for professional and personal
51
Q

Loyalty- RECOMMENDATIONS for firms

A
  • Employers should not have incentive and compensation systems that encourage unethical behavior.
  • Firms should have policies surrounding employee outside practice, employee resignation/termination, incident reporting, and employee classification.
52
Q

Standard 4(B): Additional Compensation Arrangements

A

This standard is concerned with accepting benefits that may create a conflict between a member’s interests and her employer’s interests. Do not accept any sort of compensation that competes or creates a conflict of interest w/ your employer unless WRITTEN (email is fine) permission from all parties. Clients can give gifts, as stated in Independence and Objectivity, but they should not be to persuade an employee to do something. Nonmonetary compensation may still create a conflict of interest.

53
Q

Additional compensation arrangements- RECOMMENDATIONS for CFA members

A

Make an immediate WRITTEN/EMAIL (NOT ORAL) report to the employer/ compliance officer detailing any proposed additional compensation and services. If working part-time, discuss any arrangements that may compete with their employer’s interest at the time they are hired and abide by any limitations their employer identifies.

54
Q

Additional compensation arrangements- RECOMMENDATIONS for firms

A

Details of additional compensation, including any performance incentives, should be verified by the offering party.

55
Q

Standard 4(C): Responsibilities of supervisors

A

Make reasonable efforts to ensure that anyone subject to their supervision complies with applicable laws, rules, regulations, and the Code and Standards. Make sure the firm has an adequate compliance system. A member or candidate faced with no compliance procedures or with procedures he believes are inadequate must decline supervisory responsibility in writing until adequate procedures are adopted by the firm.

56
Q

Responsibilities of supervisors- RECOMMENDATIONS for CFA members

A
  • recommend that employer adopt a code of ethics.
  • Provide code of ethics to employees and clients
  • If you are compliance officer: Update the compliance system and staff continuously
  • Require professional conduct evaluations
  • Review employee actions to monitor compliance
  • Conduct thorough investigations
  • Place appropriate limitations on wrongdoers until investigation is complete
57
Q

Responsibilities of supervisors- RECOMMENDATIONS for firms

A

An adequate compliance system should:
* Be understandable
* Have a compliance officer
* Have checks/balances
* Have procedures for reporting violations

58
Q

Standard 5: Investment analysis, recommendations, and actions

A
  • Diligence and reasonable basis
  • Record retention
  • Communication w/ clients and prospective clients
59
Q

Standard 5(A): Diligence and reasonable basis

A

Exercise diligence, independence, and thoroughness in analyzing investments. Also, have a reasonable and adequate basis, supported by appropriate research and investigation. The level of research needed to satisfy the requirement for due diligence will differ depending on the product or service offered. Make a reasonable effort to cover ALL relevant issues when arriving at an investment recommendation. If the member believes that the consensus opinion has a reasonable and adequate basis and is independent and objective, the member or candidate need not decline to be identified with the report. If the member or candidate is confident in the process, the member or candidate does not need to dissociate from the report, even if it does not reflect his or her opinion. Using secondary/third-party research is allowed as long as the research is adequately reviewed for accuracy and thoroughness.

  • If working in a group project, and all the group members have performed dilligent work but you disagree with the result, you are not required to disassociate/dissent. However, if the other group members did not perform dilligent work, you are required to disassociate/dissent.
  • A research report can specify VaR as an appropriate risk metric, but the report should clarify that the quality of the VaR estimate depends on the quality of model inputs.
60
Q

A list of things that should be considered prior to making a recommendation or taking investment action includes:

A
  • National/global economic conditions
  • Firm’s financial results and history
  • Limitations of models used
  • Peer group comparison
61
Q

Diligence and reasonable basis: RECOMMENDATIONS for CFA members

A
  • Members should encourage their firms to adopt a policy for periodic review of the quality of third-party research.
  • Have written procedures for acceptable scenario testing.
  • Procedures for evaluating outside info providers, including how often
62
Q

Standard 5(B): Communication w/ clients and prospective clients

A
  • Disclose to clients the general principles of the investment processes used to analyze investments, select securities, and construct portfolio and promptly report any updates to this process.
  • Promptly disclose any changes that might significantly affect the investment processes.
  • Disclose any risks or limitations to this process.
  • Distinguish between fact and opinion in this process.
  • Explain models used to clients and any limits of the model.
63
Q

Communication w/ clients and prospective clients- RECOMMENDATIONS for CFA members

A

Selection of relevant factors in a report can be a judgment call so members should maintain records indicating the nature of the research, and be able to supply additional information if it is requested by the client or other users of the report.

64
Q

Standard 5(C): Record retention

A

Develop and maintain appropriate records to support investment analysis. Maintain research records that support the reasons for the analyst’s conclusions. These records are property of the firm. All communications with clients through any medium, including emails and text messages, are records that must be retained.

65
Q

Record retention- RECOMMENDATIONS for CFA members

A

If no regulatory standards or firm policies are in place, the Standard recommends a seven-year minimum holding period.

66
Q

Record retention- RECOMMENDATIONS for firms

A

The responsibility to maintain records generally is the firm’s responsibility.

67
Q

Standard 6: Conflicts of interest

A
  • Disclosure of conflicts
  • Priority of transactions
  • Referral fees
68
Q

Standard 6(A): Disclosure of conflicts

A

Make full and fair disclosure of ALL matters that could reasonably be expected to impair independence and objectivity or interfere with respective duties to clients/employers. The most common conflict that requires disclosure is actual ownership of stock in companies that the member recommends or that clients hold. Another common source of conflicts of interest is a member’s compensation/bonus structure. Disclosures of conflicts should be prominent and easily understandable. Employees must comply with prohibitions imposed by their employer.

69
Q

Disclosure of conflicts- RECOMMENDATIONS for CFA members

A

Any special compensation arrangements should be disclosed.

70
Q

Standard 6(B): Priority of transactions

A

Investment transactions for clients/ employers must have priority over investment transactions in which a Member/ Candidate has a direct/indirect interest. Client accounts that belong to family members should be treated like any other account so long as there is no direct interest on the part of the analyst. Client has highest priority, then employer, then employee. Personal transactions may be undertaken only after clients and the member’s employer have had an adequate opportunity to act on a recommendation. Members must not act on information about pending trades for personal gain.

  • Persons with access to information during the normal preparation of research recommendations are subject to this standard.
  • The recommended procedures suggest investment personnel should examine all planned personal trades to identify possible conflicts before the execution of the trades.
71
Q

Priority of transactions- RECOMMENDATIONS for CFA members

A

Members can avoid conflicts that arise with IPOs by not participating in them.

72
Q

Priority of transactions- RECOMMENDATIONS for firms

A

All firms should have basic procedures in place that address conflicts created by personal investing that:
* Establish limits on employee participation in IPOs/ private placements.
* Establish blackout/restricted periods: no trading.
* Establish reporting procedures, including duplicate trade confirmations, disclosure of personal holdings and beneficial ownership positions, and pre-clearance procedures.

73
Q

Standard 6(C): Referral fees

A

DISCLOSE to employers and to AFFECTED prospects and clients, any type of compensation paid or received for the recommendation of a product/service.

  • Must disclose the payment and the estimated value of that payment.
74
Q

Referral fees- RECOMMENDATIONS for CFA members

A

Encourage employer to adopt clear procedures regarding compensation for referrals.

  • Provide employer w/ updates at least quarterly.
75
Q

Referral fees- RECOMMENDATIONS for firms

A

Firms that do not prohibit referral fees should have clear procedures for approval and policies regarding the nature and value of referral compensation received.

76
Q

Standard VII(A)

A

Do not engage in any activity that harms the reputation of the CFA Institute. This conduct includes:
* Cheating on CFA exam
* Telling other candidates about what was on the exam
* Not following rules and policies of the CFA Program
* Giving any confidential info about the CFA program to people that shouldn’t know
* Misrepresenting info on the Professional Conduct Statement (PCS) or the CFA Institute Professional Development Program.

77
Q

Standard VII(B)

A

Do not misrepresent the CFA designation. Members must sign the PCS annually and pay the annual dues.

78
Q

Standard VII(B)- Recommendations for CFA members

A

Members should be sure that their firms are aware of the proper references to a member’s CFA designation or candidacy, as errors in these references are common.

79
Q

Global investment performance standards (GIPS)

A

A set of voluntary standards used by investment managers throughout the world to ensure the full disclosure and fair representation of their investment performance. Can be presented time-weighted or money-weighted. It was created because if investment firms can report their performance however they want, there is room for biasWhen measuring and presenting their investment performance, GIPS compliant firms are required to include terminated accounts in their performance history

80
Q

Eights sections of the GIPS standards

A

Fundamentals of complianceInput data and calculation methodologyComposite and pooled fund maintenanceComposite time-weighted return reportComposite money-weighted return reportPooled fund time-weighted return reportPooled fund money-weighted return reportGIPS advertising guidelines

81
Q

Composite

A

A grouping of individual discretionary portfolios representing a similar investment strategy, objective, or mandate.Reporting on the performance of composites gives clients and prospects information about the firm’s success in managing various types of securities and results for various investment styles.A composite must include all portfolios (current and past) that the firm has managed in accordance with this particular strategy. The firm should identify which composite each managed portfolio is to be included in before the portfolio’s performance is known.Ex: Large cap stocks, investment-grade domestic bonds, etc.

82
Q

True or false: GIPS compliance must be firmwide, where the firm is the distinct business entity that is held out to clients and prospects (investment management firms)?

A

TRUE

83
Q

Discretion

A

How a firm determines which of the portfolios it manages should be included in a composite.

84
Q

True or false: Firms are encouraged to have their compliance w/ GIPS independently verified

A

True. If verification is to be done, it MUST be done by a third party.

85
Q

True or false: The GIPS-compliant firm definition must be the corporation, subsidiary, or division that holds itself out to the client as a specific business entity. If the firm has different geographic locations, this firm definition should include all the locations?

A

TRUE

86
Q

To claim compliance with the GIPS standards, a firm is initially required to present GIPS-compliant performance history for how long?

A

At least 5 years

CFA (12 decks)

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