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Which of the following would be a violation of Standard III(B), Fair Dealing?

A)
Trading for regular accounts before discretionary accounts.
B)
Having well defined guidelines for pre-dissemination.
C)
Limiting the number of employees privy to recommendations and changes.



Do not discriminate against a client when disseminating investment recommendations. If the firm offers different levels of service, this fact must be offered and disclosed to all clients. The other choices are necessary parts of the Standard. The Standard actually says to have published personal guidelines for pre-dissemination, which implies that the guidelines be well-defined.

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All of the following are violations of Standard III(B), Fair Dealing, EXCEPT a member:

A)
places a trade for the firm account before issuing a buy recommendation.
B)
telephones clients in distant cities the day after a buy recommendation is mailed to all clients because their mail service is later than the member's local clients.
C)
places a trade for her discretionary accounts before placing a trade for her non-discretionary accounts.



Standard III(B) states, "Members shall deal fairly and objectively with all clients and prospects when providing investment analysis, making investment recommendations, taking investment action, or in other professional activities.”

The term “fairly” implies that members should take care not to discriminate against a client when disseminating investment recommendations. All the responses, except for the telephoning of distant clients (which has the effect of putting them in the same position as local clients), describe a situation in which a client or group of clients is receiving preferential or detrimental treatment that is unfair.

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c

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