Phoung has a number of investment management clients. He gives discounts from his standard

investment management fee rate to clients who have $$25$ million or more in their accounts. He

also provides personalized service to these clients, regularly checking in with them by phone to

discuss new investment opportunities. Phoung:

A$,$ has not violated the Code and Standards as long as his increased level of service to

some clients has not disadvantaged other clients and he has disclosed his different

levels of service to all his clients.

B$.$ has violated the Code and Standards by not treating all his clients fairly with respect

to his investment management fees.

C$.$ has not violated the Code and Standards because the level of investment

management fees charged to clients is not addressed by the Code and Standards.