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Cindy, a CFA. is the compliance officer at a broker dealer. Two years ago, she wrote compliance procedures and made all covered employees aware of

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Cindy, a CFA. is the compliance officer at a broker dealer. Two years ago, she wrote compliance procedures and made all covered employees aware of the procedures. An external audit report noted that on several occasions over the past two years, two different employees traded in recommended securities in advance of trades made for clients. Cindy fires both employees and circulates procedures to explain clearly which activities are prohibited. Cindy has violated the Standard concerning misconduct because she was associated with the unethical activity responsibilities of supervisors by failing to implement reasonable procedures to detect violations loyalty by firing the employees instead of restricting their activities

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