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William Rogers, CFA, is a commercial insurance broker who sometimes recommends money managers to his high net worth clients. For those clients who hire the managers, the managers pay Rogers a percentage of the management fees on the account. Rogers tells prospects, “I receive referral fees from the money managers if you employ them.” Rogers has:

A violated the Standard concerning referrals.

Standard VI(C) Referral Fees requires members and candidates to disclose any referral fees they will earn from successful referrals as well as the nature of the compensation. Here Rogers must disclose that he will receive a percentage of management fees on an ongoing basis.


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