Under Standard IV(B), Lindquist is required to disclose in writing to his employer any benefits (monetary or non-monetary) he receives for services that are in addition to compensation or benefits provided by his employer. An informal discussion with his supervisor does not conform to the requirement that the notice be in writing. Under Standard VI(A), he is also required to disclose the arrangement to his clients because a directorship is a conflict of interest that could reasonably be expected to impair his objectivity. He must do so even if he currently holds no shares of Western in his clients’ portfolios because it may impair his objectivity in recommending the stock for inclusion in clients’ portfolios in the future. Lindquist violated Standard I(B) because clients could reasonably assume his objectivity is in question |
