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If he’s not giving the cards out at all its fine, just like if you wrote on a piece of paper your name, CFA to motivate yourself to do some study, you’re not giving it out its fine.
The publicly or not is meant to cover situations where a business card might be given out to a single person, its to reinforce that any dissemination of it will be a violation, just having them in your posession is not a violation.

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