VI(A) Avoid or Disclose Conflicts. You must avoid conflicts of interest where you can, and where a conflict cannot reasonably be avoided, make full and fair disclosure of all matters that could reasonably be expected to impair your independence and objectivity or interfere with your duties to your employer, clients and prospective clients. The order of those two verbs is the Standard's own title and it is the whole shape of the rule (check the current title and text at cfainstitute.org; this one was rewritten in the revision effective 1 January 2024, and an older handbook will show it as "Disclosure of Conflicts"). Avoidance is the first duty. Disclosure is what you owe when avoidance is genuinely not open to you, not a toll you can pay to keep a conflict you could simply have declined.
That ordering changes how a vignette is graded. Under a disclose-only reading, any conflict plus any disclosure equals compliance, and the analysis stops at "was it disclosed?". Under the current Standard the first question is whether the conflict had to exist at all. An analyst who accepts a board seat at a company she covers, then discloses it in every note, has disclosed a conflict she was never obliged to take on. A portfolio manager whose employer's parent underwrites an issuer he covers holds a conflict that is structural and cannot be walked away from, and there disclosure is the right and sufficient answer. The two look identical if you only check for a disclosure line.
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What three tests must a disclosure pass?
When disclosure is the answer, it has to pass three separate tests, and a vignette will usually break exactly one of them. It must be prominent, meaning positioned where the reader will actually meet it rather than buried in an appendix, a footnote or a hyperlink nobody opens. It must be in plain language, meaning the client's words rather than the compliance department's: "I own shares in this company" beats "the author may from time to time maintain positions in covered securities". And it must be communicated effectively, which is a test on the receiving end rather than the sending end. A disclosure that was made once, at onboarding, in a document the client has not seen since, has not been effectively communicated about a conflict that arose two years later. Ask, for each: prominent, plain, and did it actually reach the person it was for?
How broad is VI(A) among the conflict standards?
Within the four conflict-flavoured Standards this remains the broadest, reaching board seats, personal ownership stakes in a covered company, cross-holdings between a firm and an issuer it covers, and family relationships with a company's management, whenever any of them could colour a recommendation. Route the narrower three first, as section 10 sets out, and let VI(A) catch what is left. What has changed is what "catching it" now requires: not a disclosure somewhere in the file, but an avoidance decision that was actually considered, and a disclosure that is prominent, plain and delivered.