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Jim Bennett, CFA, leases office space to his best friend, Steve Waters. Bennett is an independent investment advisor specializing in high net worth clients and Waters is a licensed life insurance underwriter. In lieu of paying rent, Waters refers his insurance clients to Bennett, but only with the clients’ permission. For clients referred by Waters, Bennett: A. must disclose the terms of the lease arrangement. B. need not disclose the terms of the lease arrangement because Waters obtained the clients’ permission for the referral. C. need not disclose the referral fee if Waters discloses the lease arrangement to the clients first. |