A CFA recommends investment advisers to high net worth individuals. Investment advisers pay a portion of their investment management fees as compensation for client referrals. When a client inquires with the CFA about his/her criteria for recommending managers, the CFA indicates that managers are selected based only on historical performance versus a universe of comparable peer investment managers, but does not mention the compensation arrangement. The CFA has most likely violated the Standard concerning: misrepresentation fair dealing referral fees