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Toni Florence, CFA, CAIA, leases office space to her best friend, Tom Rigs. Florence is an independent investment advisor specializing in high net worth clients and Rigs is a licensed real estate broker. In lieu of paying rent, Rigs refers his real estate clients to Florence, but only with the clients’ permission. For clients referred by Rigs, Florence: A. need not disclose the referral fee if Rigs discloses the lease arrangement to the clients first. B. must disclose the terms of the lease arrangement. C. need not disclose the terms of the lease arrangement because Rigs obtained the clients’ permission for the referral. |