Explanation : According to Standard IV(C) Responsibilities of Supervisors, a member or
candidate should decline in writing to accept supervisory responsibilities
until reasonable compliance procedures are laid down by a firm for her to
assume and exercise responsibility.
Explanation : Crawford doesn’t own the same securities as his clients therefore he least
likely violates Standard VI(B) Priority of Transactions. He violates
Standard VI(A) Disclosure of Conflicts by failing to inform his clients of
the change in his compensation arrangement with his employer which
causes a conflict between his compensation and the clients’ IPS. He
violated III(C) Suitability because high-yield bonds are not suitable for
his risk-averse clients.
Explanation : Standard III(A) Loyalty, Prudence and Care has been violated because
Toffler did not place his clients’ interests before his employer’s interests.
Standard VI(B) Priority of Transactions has been violated. Toffler would
have avoided the conflict by waiting until his clients had the opportunity
to receive and assimilate Gates’ report. The report was sent out to all
clients at the same time; hence Standard III(B) Fair Dealing is not
violated.
Explanation : Standards IV(A) Loyalty and IV(C) Responsibility of Supervisors have
been violated since both the supervisor and compliance officer did not
investigate Sonali’s concerns. There is no evidence of misrepresentation.
Explanation : No violation has occurred. It is acceptable to share past performance as
long as a clear disclaimer is provided that this performance was achieved
at another firm.