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Archer Clegg, CFA, manages a fund of illiquid distressed real estate that primarily consists of properties located in economically depressed areas. Clegg does not report

Archer Clegg, CFA, manages a fund of illiquid distressed real estate that primarily consists of properties located in economically depressed areas. Clegg does not report fund performance relative to a benchmark since there are no benchmarks based on distressed real estate. Clegg uses two reputable appraisal firms to value each property annually. Last year, a new appraisal firm was hired due to cost and timing concerns involving a previous appraiser. Since then, Clegg has noticed that the new firm appears to consistently undervalue properties compared with the other firm doing appraisals. Fund performance reports are prepared using the average of the two appraisals, a method that is disclosed to clients and potential clients. Has Clegg most likely violated Standard I(C) Misrepresentation? A No. B Yes, since he is not using only the lowest appraisal. C Yes, since he fails to compare performance to a benchmark

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