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Ovitz cannot rely on disclosures made by StatInvest but must disclose the referral arrangement to clients and prospects herself. It does not matter that a general overhead account is designated as the source of funds for the research purchased from StatInvest. Ryers & Ovitz Inc. and StatInvest have an agreement which provides a form of compensation to both parties and may pose a cost to the client either directly or indirectly. In order to assess the full cost of either firms’ services, the client must be aware of the referral arrangement. By not actively disclosing the agreement, Ovitz has violated Standard VI(C) Referral Fees