10、Alexander Newton, CFA, is the chief compliance officer for Mills Investment Limited. Newton institutes a new policy requiring the pro rata distribution of new security issues to all established discretionary accounts for which the new issues are appropriate. The policy provides for the distribution of new issues to newly established discretionary accounts after the one-month anniversary date. This policy is disclosed to all existing and potential clients. Did Newton violate any CFA Institute Standards of Professional Conduct? A. No. B. Yes, because the distribution policy fails to treat all discretionary accounts equally. C. Yes, because disclosure of inequitable allocation methods does not fulfill the duty for fair and equitable trade allocation procedures. D. Yes, because the discretionary accounts for which the new issues are not appropriate should still be offered the chance to participate in the offerings.
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