Olsen is president and CEO of RCS, a registered investment adviser. RCS offered clients an advisory fee between 0.4% and 1.5% of their assets under management based on fee breakpoints described in its fee schedule. The schedule reduced the advisory fee as a client's assets under management increased. RCS's fee schedule was incorporated by reference in client advisory agreements, distributed to clients upon request, and disclosed in RCS's regulatory disclosure filings. RCS's written policies and procedures manual stated that RCS was to conform its client fees and fee billing practices to those described in the regulatory filings in the advisory agreements provided to clients. In certain instances, however, RCS failed to apply the breakpoint discounts. As a result, RCS improperly calculated advisory fees and thereby overcharged certain clients. As president and CEO, Olsen O a. met his ethical responsibilities if he delegated responsibility for billing and fees to competent personnel in RCS's accounting department. O b. met his ethical responsibilities if he made certain that appropriate policies and procedures were in place to ensure that RCS properly billed its clients. O c. met his ethical responsibilities if the erroneous billing was the result of clerical error and inadvertent. O d. failed to meet his ethical responsibilities.