ethics - referral fee 

Ken Kawasaki,CFA,shares a building with a number of other professionals who are also involved in the investment management business.

Kawasaki makes arrangements with several of these professionals,including accountants and lawyers,to refer clients to each other. An informal score is kept on the expectation the referrals will equal out over time, eliminating the need for any cash payments. Kawasaki never mentions this arrangement to clients or prospective clients.Does Kawasaki's agreement with the other building occupants most likely violate any CFA Institute Standards of Professional Conduct?

虽然后面句子说了：介绍的过程保持公平性，所以互相之间没有介绍费

但是实质上是有介绍费的，因为我给他介绍客户，他也给我介绍客户，那么给我介绍回来的这个客户就是一种变相的介绍费

所以这种安排要披露给客户，而K同学并没有披露，所以违反介绍费这一条。

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