Carla Bersollini is a portfolio manager for a balanced fund. Amongst her clients are also her parents who are fee-paying like all the rest. Bersollini has beneficial ownership in her parents account and is required by her firm Gallant Investment Company preclearance and reporting requirements for personal transactions. When a certain hot IPO becomes available she advises the brokers to buy shares for her parents account first if its suitable for her parents and herself and then does she place the remaining order with her clients, keeping their suitability in mind. She doesnt report the transaction. Bersollinis supervisor, Carlo Pagni, does not have any procedure in place in review the transactions executed by his subordinates