为啥lim也违反了

问题如下：

Jerome Foster, CFA, is the CEO of Foster Asset Management and the chair of the firm’s Investment Committee. Twenty years ago, he started the firm with 2 employees, and it has grown to 25 employees, of whom 5 are investment managers. Foster’s clients range from individuals with very conservative risk profiles allowing only money market instruments to large institutional investors with higher risk tolerance profiles. Foster is looking to further expand his business through acquisitions of privately owned asset management companies. He informs Mercy Ogalo, CFA, the head of compliance and risk, of his plans to be out of the office for extended periods of time while conducting initial interviews and due diligence visits.

In a surprising turn of events, Constantile Life, a publicly listed insurance firm that wishes to enter the asset management industry, approaches Foster. It is interested in buying Foster Asset Management to complement its product line and to significantly increase its profitability. Constantile presents an extensive list of documents the firm wants to examine as part of its due diligence process. Foster updates Ogalo about the potential buyer and asks her to help gather the due diligence documents, including the contact information of all the current board members and other shareholders, as well as copies of all the firm’s policies and procedures. Ogalo mentions to Foster that she has yet to complete her statutory annual review of the policies and procedures.

Ogalo walks into Foster’s office to update him on the gathering of due diligence documents requested by Constantile and finds Foster on the phone. He motions for her to take a seat and hands her a note indicating he is talking with the potential buyer. She overhears Foster tell the buyer, “We haven’t lost a client in over five years. We’ve been able to outperform the market on a consistent basis, so our clients love us!” Ogalo knows the comment about the firm outperforming the market is likely to be true, but the firm lost two clients just in the last month owing to increasing management fees.

As a condition of purchasing his firm, Constantile requires Foster to remain the CEO for three years. After the three years, he would be eligible for a significant retirement package if he met certain key performance indicators, including above-average investment performance. They agreed the performance measurement would be based on the recommended procedures for compliance with Standard III(D): Performance Presentation—specifically,

• Procedure 1: The firm will create and track weighted composites of similar portfolios based on their risk profiles.
• Procedure 2: When performance includes simulated results due to the introduction of new products, it will be clearly stated in the performance presentation.
• Procedure 3: Terminated accounts will be removed from the performance history after 10 years.

In the first Foster Asset Management board meeting after the sale, Calvin Lim, CFA, the firm’s chief investment officer (CIO), stated, “My investment team recently added real estate investment trust (REITs) to our model portfolio to see what the impact would be on investment returns for our clients if we added them to their portfolios. But this asset class has a much higher risk profile than our normal allowable assets.” Foster added, “After we analyzed the impact of adding this new asset class to our model portfolio, we made the decision to add the real estate exposure to all of our client accounts. We found it is having a positive impact on portfolio returns and still complies with the firm’s performance measurement policy.”

After her annual review of the firm’s policies and procedures, Ogalo decided to make some changes to strengthen monitoring procedures for the supervisors. Subsequently, Ogalo presented the proposed changes to the board for approval. She mentioned that the suggested changes specifically enhance the requirements for the firm’s supervisors. The changes are as recommended by the CFA Institute Standards of Professional Conduct. If approved by the board, supervisors would be required to implement the following policy changes once they detect a violation of the firm’s policies:

• Policy 1: Give the employee a warning to cease the activity.
• Policy 2: Place limits on the employee’s activities.
• Policy 3: Report the misconduct up the chain of command.

During Lim’s presentation to the board of directors, who mostly likely violated Standard III: Duties to Clients?

选项：

A.Lim

B.Foster

C.Lim and Foster

解释：

根据CFA Institute的《道德规范与专业行为准则》，标准 III(A) 忠诚 、谨慎和仔细，要求履行对客户的忠诚、谨慎和仔细责任。Lim提到增加的资产类别（房地产投资信托）明显超出了客户账户的正常风险范围，这意味着可能没有充分告知客户潜在的风险。Foster也未能明确说明该投资决策是否符合所有客户的投资目标和风险承受能力。