IV(B.8) Disclosure of Referral Fees: Members shall disclose to clients and prospects any consideration or benefit received by the member or delivered to others for the recommendation of any services to the client or prospect.

　　Compliance:

　　1. Disclose all agreements in writing to any client or prospect who has been referred.

　　2. Describe in the disclosure the nature of the consideration and the estimated dollar value of the consideration.

　　3. Consult a supervisor and legal counsel concerning any prospective arrangement regarding referral fees.

　　2-V.: Standards of Professional Conduct: V. Relationships with and Responsibilities to the Investing Public

　　A.: Prohibition against Use of Material Nonpublic Information

　　Standard: Members who possess material nonpublic information related to the value of a security shall not trade or cause others to trade in that security if such trading would breach a duty or if the information was misappropriated or relates to a tender offer. If members receive material nonpublic information in confidence, they shall not breach that confidence by trading or causing others to trade in securities to which such information relates. Members shall make reasonable efforts to achieve public dissemination of material nonpublic information disclosed in breach of a duty.

　　Compliance: Fire walls, minimum elements are:

　　1. Control over interdepartmental communications.

　　2. Review employee trading against restricted lists.

　　3. Restrict proprietary trading while the firm is in possession of material nonpublic information.

　　Additional procedures:

　　1. Restrict personal and proprietary employee trading.

　　2. Place securities on a restricted list when the firm has material nonpublic information.

　　3. Disseminate material nonpublic information only to those with a need to know.

　　4. Designate a supervisor who decides when trading is appropriate.

　　B.: Performance presentation

　　Standard:

　　1. Members shall not make any statements, orally or in writing, that misrepresent the investment performance that they or their firms have accomplished or can reasonably be expected to achieve.