CFA PCP Investigations

As if the CFA exam is not stressful enough.


You are nervously awaiting your exam results then out of the blue comes a letter that states that you are under a Professional Conduct Program (PCP) investigation with the threat of a voided exam result because of suspected cheating during the CFA exam. WTF? Seriously?

Try not to panic nor to reply with a hasty emotional and apologetic e-mail to the CFA Institute investigator. Put the letter aside and take a deep breath. Recall what actually happened and how you can effectively counter the allegations. Take a few days to write down your thoughts into a cohesive, concise account.


I advise against hiring a lawyer to handle your response. You can reply yourself in a way that convenes what actually happened without adopting an adversarial legal tone from the outset. You will also save a lot of money and the frustration of overpromises. Remember that you are not in court nor have you been found to have done anything illegal (unless you punched a proctor). The PCP process is supposed to fair for everybody, so it makes no sense to me how a lawyer can actually help you. I know of candidates who have been unsuccessful, despite hiring expensive lawyers and sending pages of detailed counter evidence.


Sadly, I also know of candidates who have cheated during the CFA exam, succumbing to desperate temptation, just like Mr. Bean pictured above (he mistakenly studied for trigonometry though the exam was on calculus). The CFA cheaters rightfully deserve their comeuppance, and for this, the PCP shines to protect the integrity of the CFA exam and reward the crazy hard work of honest writers.

Whatever happened to receive the PCP investigation letter, keep in mind that nobody is perfect. What a terrible, boring world if we were perfect. Yes, you are being judged by some anonymous investigator whom you will never meet. Get over it.


Above all else: don't let your mind run away with imagined bad outcomes. I once met a candidate under investigation in Canada who was immigrating and awaiting her Permanent Residence (PR) card; she panicked when she received her PCP letter (wrongly) thinking that she would be deported and denied Canadian citizenship. It would be nice if those in charge of these investigations at CFA Institute would empathize with candidates who wrongly receive these worrisome letters. I'm not sure that apologies are issued; I doubt it.


The good news: ​the candidate was cleared of any ethical wrongdoing. The greatest news: she passed the CFA Level III exam and completed the CFA Program once the PCP investigation was closed.

Get in touch if you'd like to talk about your PCP investigation letter. I know the feeling. I once received one of those shocking PCP investigation letters, too, but not because of alleged exam-day misconduct. But rather as a revenge tactic from somebody I used to know. I will tell you how I reacted to and then responded to the PCP investigation letter. Thankfully, the matter was successfully resolved within a couple of weeks. (And my gut instinct about my vindictive first wife were once again fully confirmed almost six years after our "amicable" divorce).


There are worse things in life than a CFA PCP investigation.

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Daren E. Miller

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