Hern Investments provides monthly emerging market research

Hern Investments provides monthly emerging market research

Hern Investments provides monthly emerging market research to BakerBrokerage in exchange for prospective client referrals and European equityresearch from Baker. Clients and prospects of Hern are not made aware of the agreement, but clients unanimously rave about the high quality of the research provided by Baker. As a result of the research, many clients with nondiscretionary accounts have earned substantial returns on their portfolios.Managers at Hern have also used the research to earn outstanding returns for thefirm’s discretionary accounts. Hern has most likely:A. not violated the Code and Standards.B. violated the Code and Standards by using third-party research indiscretionary accounts.C. violated the Code and Standards by failing to disclose the referral agreementwith Baker.

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