I(D): Misconduct

Does Lazar *most likely* violate the Code and Standards by charging a discounted rate to a specific client?

Correct! Although the client has a lower rate, it’s clear that the client does not receive the full services of the firm. This fact indicates that it was appropriate for Lazar to offer a discounted rate. So as long as Lazar is not discriminating between investment clients, he is not in violation of the Code and Standards.

Incorrect. Some clients are paying the fees disclosed in the marketing materials, so the firm is not misrepresenting its fee structure.

Incorrect. The client does not receive more personalized or special services that the firm offers.

No

Yes, because Lazar has misrepresented his firm’s fees

Yes, because Lazar is showing favoritism for a client from his home country