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C. Referral Fees.
#analyst-notes #and-actions #code-of-ethics-and-standards-of-professional-conduct #vi-conflicts-of-interest
C. Referral Fees.

You must disclose to your employer, clients, and prospective clients, as appropriate, any compensation, consideration, or benefit received by or paid to others for the recommendation of products or services.

Such disclosure should help the client evaluate any possible partiality shown in any recommendations of services as well as evaluate the full cost of services.

You are required to:

  • Disclose the existence and terms of any referral fee agreements to all clients or prospects who have been referred under such agreements.
  • Describe the nature of the consideration and its estimated dollar value in this disclosure. Consideration includes all fees, whether paid or not (in cash, in soft dollars, or in kind).
  • Consult a supervisor and legal counsel concerning any prospective arrangement regarding referral fees.
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