Business PracticesPregunta 59 de 100
An investment adviser deposits a client's advance advisory fee into the firm's general operating account and uses it to pay office rent. This conduct is:
a.Acceptable because the fee had already been earned on paper
b.Commingling of client funds with firm assets, a prohibited business practice
c.Acceptable if the client is later refunded
d.Permitted for any adviser with a surety bond
Explicación
Client funds and securities must be kept separate from firm assets, and mixing them exposes clients to the firm's creditors and obscures the audit trail. Prepaid fees that have not yet been earned belong to the client and must be handled under the applicable custody and prepayment rules. Neither a later refund nor a surety bond makes commingling permissible.
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