I(C): Misrepresentation

Anthony Modela, CFA, runs his own investment advisement office. For his private clients, he publishes a monthly private client letter. He also publishes a monthly investment newsletter for free and to the public, in which he sometimes includes stock analysis provided by the issuer for which he was paid by the issuer of the stock. Since the newsletter is public and free, he does not disclose that he was paid by the issuer. However, in his private client letter, he always discloses if he was paid by the issuer. Regardless of whether he is paid by the issuer or not, Anthony's own recommendations are always his own work. It is _most likely_ that Anthony is:

Correct. Anthony is violating Standard I(C): Misrepresentation by including an analysis in the newsletter without disclosing that the analysis is not his own work. In addition, Anthony is violating Standard VI(A): Disclosure of Conflicts by not disclosing that he is being paid by the stock issuer.

Incorrect. Even though the analysis and recommendations are Anthony’s own work, that does not relieve him of his obligations under CFA Institute Standards.

Incorrect. There is no distinction between information supplied to private clients versus the public as a whole.

violating CFA Institute Standards because he must always disclose that he was paid by an issuer to include analysis and recommendations.

not violating CFA Institute Standards because he is not required to disclose he was paid by an issuer as long as his analysis and recommendations are his own work.

not violating CFA Institute Standards because he is disclosing that he was paid to his private clients, and he is not required to disclose that he was paid in a free, public newsletter.