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Jessica French is an individual investment advisor with 200 clients and claims she conforms to Global Investment Performance Standards (GIPS). French includes all of the clients on her books. One of those clients is her father, to whom she charges no fee. However, she manages that portfolio using the same processes as she uses for her paying clients. Another client included in the composite is John Randolph, a wealthy entrepreneur. Randolph is the only client who does not give her discretion over the assets and makes every decision himself, getting suggestions from French and using her to implement decisions. French: A. has violated GIPS because it includes Randolph's account, but not because it includes her father's account. B. conforms to GIPS, if disclosures are made about the non-fee-paying account. C. has violated GIPS because it includes her father's account, but not because it includes Randolph's account. |