When Ed Michaels, CFA, accepted the compliance officer position at a broker-dealer two years ago, he wrote compliance procedures and made all covered employees aware of the procedures. A report by an external auditor found that on several occasions over the past two years, two different employees traded in recommended securities ahead of trades made in managed client accounts. Michaels fires both employees and recirculates the written compliance procedures that explain clearly which activities are prohibited. Michaels has violated the Standard concerning:
A.Loyalty by firing the employees instead of restricting their activities.
B.Misconduct because he was associated with the unethical activity.
C.Responsibilities of supervisors by failing to implement reasonable procedures to detect violations.
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