bmaggie

Vijay Gill, CFA, leases office space from Land Bank in exchange for an agreement that Gill will pay Land 20% of any fees paid by Land customers to Gill for investment management services. Gill also has an arrangement with Bloom Insurance Advisors whereby Gill receives a fee for each client referred. Gill only refers clients that request insurance products. Gill meets with Randolph Song, a Land Bank customer, who is interested in Gill’s asset management services as well as insurance products. Gill is required to disclose to Song:

A) the terms of the arrangement with Bloom, but not the terms of the arrangement with Land Bank.

B) neither the Land Bank nor Bloom arrangements, but may disclose them if he chooses to do so.

C) the terms of the arrangements with both Land Bank and Bloom.

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Standard VI(C) Referral Fees requires members to disclose to clients and prospects any consideration or benefit received by the member or delivered to others for the recommendation of any services to the client or prospect. Gill is delivering a benefit to Land Bank and receiving a benefit from Bloom, both of which must be disclosed to Song.