Which of the following does NOT violate Standard III(B): Fair Dealing?

A) A portfolio manager allocates IPO shares to her brothers fee-based retirement account only after allocating shares to all other accounts.

B) Before disseminating a change in the analysts buy recommendation, the analyst calls his best clients and tells them about the change.

C) After releasing the general recommendation to all clients, an analyst calls the firms largest institutional clients to discuss the recommendation in more detail.

D)A firm makes investment recommendations and also manages a mutual fund. The firm routinely begins trading for the funds account ten minutes before announcing recommendation changes to client accounts.