9.11 - Dishonest and Unethical Business Practices of Broker/Dealers and Agents
An agent receives a notice of execution for 500 shares on a customer's order for only 400 shares. Which of the following actions should he take? A) Report the problem immediately to his supervisor. B) Promptly report the execution of 500 shares to the customer and waive commissions on the overage. C) Promptly sell the 100 share overage at the best available price. D) Break the trade within five minutes, enter a corrected order, and place the transaction on the error log.
Answer: A Agents generally do not fix errors. Agents should report errant trades to a supervising principal immediately.
A 78-year-old retiree has a $100,000 CD maturing and is dissatisfied with current yields on CDs. Aside from Social Security and a monthly pension, the $100,000 is his total liquid net worth. The agent recommends investing the funds in a single premium immediate variable annuity and allocating funds to the separate account as follows: Medical Technology $10,000 High Yield Corporate $40,000 Growth & Income $50,000 The agent's recommendation is: A) unsuitable primarily because of the customer's age, objectives, and risk tolerance. B) suitable provided the customer agrees with the recommendation. C) suitable because it appears probable to increase the value of his holdings as well as to generate increased income. D) unsuitable primarily because of the customer's probable liquidity needs.
A) unsuitable primarily because of the customer's age, objectives, and risk tolerance. B) suitable provided the customer agrees with the recommendation. C) suitable because it appears probable to increase the value of his holdings as well as to generate increased income. D) unsuitable primarily because of the customer's probable liquidity needs. Click for Answer and Explanation Answer: A With half of the investment allocated to medical technology and high-yield separate accounts, which carry a higher risk, the allocation seems unsuitable for a 78-year-old needing this monthly income.
Abel Kane is an agent for Garden City Securities, a broker/dealer registered with the SEC and all 50 states. It would be considered an unethical or dishonest business practice for Mr. Kane to fail to make prompt delivery of certificates when requested by the customer fail to obtain written authorization for a discretionary account prior to the first trade in that account accept an order from a client's spouse without written trading authorization prior to receiving the order share commissions with another agent registered with Garden City Securities A) II and III B) I, II, and III C) I and IV D) III and IV
Abel Kane is an agent for Garden City Securities, a broker/dealer registered with the SEC and all 50 states. It would be considered an unethical or dishonest business practice for Mr. Kane to fail to make prompt delivery of certificates when requested by the customer fail to obtain written authorization for a discretionary account prior to the first trade in that account accept an order from a client's spouse without written trading authorization prior to receiving the order share commissions with another agent registered with Garden City Securities A) II and III B) I, II, and III C) I and IV D) III and IV
A customer needs $10,000 to pay for a new house within the next year. His agent suggests that he invest in a stock that has been performing extremely well the past year and assures the customer that he cannot go wrong. According to the Uniform Securities Act, this is an: unethical business practice. example of guaranteeing a profit. example of flamboyant language. unsuitable investment
Answer: A All the choices listed are true.
According to North American Securities Administrators Association's (NASAA) Statement of Policy on Dishonest or Unethical Business Practices of Broker/Dealers and Agents, which of the following practices is NOT unethical? A) An agent of a broker/dealer exercised discretion in deciding the time that a sale took place during the trading day without expressed written discretionary authority. B) Within the first ten days of a client's initial transaction, an agent accepted oral discretion and purchased securities on behalf of the client. C) To protect the client in a declining market, an agent sold all shares in the client's account when the client had only authorized the sale of 30% of the shares. D) An agent sold shares at a price less than authorized by a client.
Answer: A An agent of a broker/dealer may exercise discretion in deciding the time or the price at which a sale takes place during the trading day without express written discretionary authority. Such action is not unethical because time and price are not considered true discretion. An agent may not exercise discretion over the number of shares to be sold without prior written discretionary authority. Oral discretion is only permitted for investment advisers and their representatives, (never broker/dealers or agents), during the first 10 days after the initial discretionary transaction in the account.
Discretion is exercised when securities professional determines all of the following EXCEPT: A) time or price. B) to buy or sell a particular security. C) number of shares. D) dollar amount of trade.
Answer: A Determining control over the time or price of an order does not constitute discretion.The selection of the number of shares or the dollar amount of a trade constitutes discretion. When a registered securities professional (B/D, agent, IA, or IAR) determines what to buy or sell or the number of shares to be bought or sold, that person is exercising discretion.
Which of the following would be prohibited practices under state securities law? Soliciting orders for exempt securities. Making recommendations on the basis of nonpublished analysts' reports. Failing to inform a client of unusually high commissions because the client does not complain. Failing to obtain prior written authority for orders from a third party A) III and IV. B) I and II. C) I and III. D) I, II and III.
Answer: A Failing to inform a client of unusually high commissions and not obtaining prior written approval for orders from a third party are prohibited practices. Soliciting orders for a security that is exempt from registration is a normal business practice. An agent may use the nonpublished reports of his firm's securities analysts as a basis for recommendations providing the nonpublished reports do not contain inside information.
An investment adviser representative may share in the profits and losses of a customer's account: A) under no conditions. B) provided a written contract is executed between the investment adviser and the client. C) as long as both the customer and the representative's employer agree and the sharing is done based on proportionate contributions to the account. D) if the investment adviser representative deducts the advisory fee charged the customer from any profits earned.
Answer: A Investment adviser representatives are not allowed to share in the capital appreciation or depreciation of their customers' accounts in the same manner as are agents
According to NASAA's Statement of Policy on Unethical and Dishonest Business Practices of Broker/Dealers and Agents, all of the following practices are considered unethical for an agent EXCEPT: A) selling 3,000 shares of ABC as directed by a client at a price that the agent determines, without oral or written discretionary authority. B) receiving written discretionary authority from a client within 20 days of first obtaining oral authority from the client. C) determining the quantity of a specific security to purchase once the client has designated that security and the action to be taken. D) selling 3,000 shares of ABC at a price the agent determines is the best the client can get, without oral or written discretionary authority.
Answer: A It is not unethical for an agent to choose time and price of a trade as long as the client has determined the asset, the action, and the amount. Discretionary authority must be received by agents in writing prior to any discretionary trading taking place in the account.
An agent of a broker/dealer has a client who lost her job but will be starting a new job in three weeks. The client is in need of $900 for the three week gap. Under what circumstances may the agent arrange a loan for the client? A) If the client has $5,000 in her brokerage account B) If the loan is less than $1,000 C) If the client is agent's niece D) If the loan is repaid within 30 days
Answer: A Loans may be made to clients if the person making the loan is in the lending business. Broker/dealers are permitted to lend money against securities held in client's portfolios. This is known as a margin loan. In fact, with $5,000 in the account, current regulations would permit a loan of up to $2,500.
With regard to the NASAA Statement of Policy on Dishonest and Unethical Business Practices of Broker/Dealers and Agents, proscribed actions would include: accepting an order from a third party after written trading authorization has been received forwarding a written complaint from a customer to the appropriate supervisory person offering to repurchase a security at its original cost if it does not increase in value borrowing money from a client who was the agent's college roommate A) III and IV B) I and II C) I, II, and IV D) II and IV
Answer: A Prohibited actions under the policy would be guaranteeing a client against loss by agreeing to repurchase a security at its cost and borrowing money from a client who is not in the money-lending business.
ABC Securities, Inc., is a full service broker/dealer. When underwriting an IPO, ABC holds on to some of its allocation in hopes that the stock will appreciate in secondary market trading. In so doing, ABC: A) is in violation of NASAA's Statement of Policy on Unethical Business Practices of Broker/Dealers and Agents. B) is acting in accordance with the Uniform Prudent Investor Rule. C) is enabling the new issue to become seasoned. D) has the potential for additional income to compensate for the risks in underwriting an IPO.
Answer: A The NASAA Statement of Policy on Dishonest or Unethical Business Practices of Broker/Dealers and Agents prohibits a broker/dealer from failing to make a bona fide public offering of all of the securities allotted to a broker/dealer for distribution, whether acquired as an underwriter, a selling group member, or from a member participating in the distribution as an underwriter or selling group member.
An agent has a new client who is prone to tergiversation. As such, it would probably make sense to A) accept unsolicited orders only B) open a discretionary account C) make recommendations on a frequent basis D) obtain permission from both the client and the broker/dealer before sharing in the profits and losses in the account
Answer: A Those who tergiversate repeatedly change their attitude or opinions. As a consequence, the client who likes an agent's recommendation one day may quickly change his mind the next. Therefore, the agent could be placed in an untenable position, being unable to satisfy the client. To avoid this possibility, it would be most sensible to leave all the decisions to the client and only accept unsolicited orders.
Under the USA, the term guaranteed refers to all of these EXCEPT: A) capital gains. B) dividends. C) interest. D) principal.
Answer: A When a security is guaranteed, that means that someone other than the issuer has guaranteed timely payment of interest and principal on a debt security, or the payment of dividends on an equity security. No one ever guarantees that the investor will have a capital gain.
Sally Megabyte is an agent with a broker/dealer. She has used her degree in computer science to develop her own stock picking software program. Backtesting has shown that the program is likely to produce returns that beat the overall market. As a result, Sally plans to use this program for each of her clients. Sally: A) is going to make her clients very happy. B) is violating suitability requirements. C) is engaging in an unethical business practice. D) must make the details of how the program works available to all who request it.
Answer: B The point here is not whether or not Sally's program works. It would be unlikely that all of her clients have the same objectives and financial resources. In fact, some of them might be suitable for debt securities rather than stocks. Therefore, using the same software program to pick stocks for every client would probably be violating the rules dealing with suitability. This would be the same if Sally were an IAR. Please note that while this might be considered an unethical business practice, the suitability choice is more to the point.
Under which of the following circumstances can an agent conduct customer transactions without the activity being recorded on the books and records of his broker/dealer employer? A) The customer is a member of the agent's immediate family. B) The transactions are authorized in writing by the broker/dealer before execution of the transactions. C) The securities are exempt under the Uniform Securities Act. D) The agent will receive no compensation.
Answer: B Under the NASAA Statement of Policy on Dishonest or Unethical Business Practices of Broker/Dealers and Agents, it would be considered contrary to the standards imposed for an agent to effect securities transactions not recorded on the regular books or records of the broker/dealer which the agent represents, unless the transactions are authorized in writing by the broker/dealer before execution of the transaction.
Answer: C When selling securities, agents are prohibited from enacting transactions that are not recorded on the broker/dealer's books unless the transactions are authorized in writing by the broker/dealer prior to execution. Failure to do this is known as selling away. Receipt of notification is not the same as authorization.
Answer: B When a broker/dealer receives a written complaint from a customer, it must document that complaint and begin an investigation as to the complaint's merits. Part of that procedure would be sending a written acknowledgment to the client that the complaint has been received.
Which of the following practices violate(s) NASAA's Statement of Policy on Dishonest or Unethical Business Practices of Broker/Dealers and Agents? Recommending the purchase of a security solely on the basis of the issuer's properly published press release regarding a likely increase in earnings per a new product branding strategy. Placing customer's fully paid securities into an account with the broker/dealer's own securities. Effecting a transaction with no change in beneficial ownership. Conducting securities transactions in a private capacity, in properly registered securities, not reflected on the books of the broker/dealer and without the knowledge and supervision of the employing broker/dealer. A) II and III. B) II, III and IV. C) I, II, III and IV. D) I only.
Answer: C According to North American Securities Administrators Association's (NASAA) Statement of Policy on Dishonest or Unethical Business Practices of Broker/Dealers and Agents, agents may not recommend securities without reasonable basis. A company press release regarding a new branding strategy is not adequate reason to recommend a security. Before making a recommendation, the agent must seek further confirmation of the anticipated positive results of the new strategy. Additionally, customer's fully paid securities must be placed in segregated accounts, not commingled with those of the broker/dealer. Effecting transactions with no change in beneficial ownership is a form of market manipulation in conflict with NASAA's Statement of Policy. Conducting securities transactions not reflected on the books of the employing broker/dealer and without the employing broker/dealer's prior written authorization is known as selling away, considered by NASAA to be an unethical practice.
Under the Uniform Securities Act, it is permissible for an agent to: solicit transactions in unregistered exempt securities. share in the profits in an account with a customer with written permission of the customer and the broker/dealer. split commissions with another agent at an affiliated broker/dealer. charge larger commissions because of a larger array of services the agent's firm offers. A) I and II. B) I, III and IV. C) I, II, III and IV. D) I only.
Answer: C All of these are permissible actions. Exempt securities are unregistered because they are exempt and solicitations for trades are no problem. Sharing in the profits in an account with a customer is permitted under these conditions, and splitting commissions with agents of the same broker/dealer or different broker/dealers under common control is also permitted. However, two registered agents representing nonaffiliated broker/dealers may never share commissions. The Uniform Securities Act does permit commission charges to reflect the quality and quantity of services provided to the client.
Which of the following is the least suitable mutual fund transaction? A) Encouraging an investor in his early 30s to invest in an emerging markets mutual fund. B) Encouraging an investor in a high-tax bracket with an income objective to invest in a municipal bond fund. C) Encouraging a mutual fund shareholder to switch from one fund family to another while a deferred load is in existence. D) Encouraging a retired 65-year-old investor to invest a small percentage of his savings in a large-cap growth fund.
Answer: C Encouraging a mutual fund shareholder to switch from one fund family to another while a deferred load is in existence is not in the client's best interest, as the client might be subject to substantial additional sales charges.
Answer: A When a security is guaranteed, that means that someone other than the issuer has guaranteed timely payment of interest and principal on a debt security, or the payment of dividends on an equity security. No one ever guarantees that the investor will have a capital gain.
Answer: C Matched orders occur when one or more broker/dealers engage in buying and selling between themselves for the purpose of creating the misleading appearance of increased activity in a security. A wash trade is an attempt to manipulate a security's price by creating an apparent interest in the security that really does not exist. Arbitrage is the simultaneous buying and selling of the same security in different markets to take advantage of different prices. It is not a form of market manipulation. Churning is a prohibited activity, but has nothing to do with the market, just a client's account.
An agent's recommendation for the purchase of a municipal security to a customer who wants fixed income and is in a relatively low tax bracket would in most cases be: unsuitable and unethical. a securities felony. grounds, in extreme cases, for suspension or revocation of the agent's license. outside regulatory jurisdiction A) II and III. B) IV only. C) I and III. D) I only.
Answer: C Municipal bonds provide a fixed income, but they are generally suitable only for high tax-bracket individuals. In this case, such a recommendation is probably unethical and could result in suspension or revocation of the registered agent's license.
One of the most prevalent schemes abusing seniors is one where the individual or couple receives an invitation to attend an educational seminar held at an upscale location. This scheme is commonly referred to as: A) senior seminar. B) wealth preservation session. C) free lunch. D) lunch and learn.
Answer: C There is probably no other area of abuse directed at seniors that has received the attention of the "free lunch" seminars.
An agent made written disclosure to his employing broker/dealer that he intends to execute a series of private securities transactions with clients who do not have accounts with his broker/dealer. The agent did not acquire express written permission from the broker/dealer and did not receive compensation for executing the transactions, but did receive written acknowledgment of receipt of the agent's notice. In this case, the agent: A) performed a matched trade. B) complied with the regulations. C) is guilty of selling away. D) engaged in an agency cross transaction.
Answer: C When selling securities, agents are prohibited from enacting transactions that are not recorded on the broker/dealer's books unless the transactions are authorized in writing by the broker/dealer prior to execution. Failure to do this is known as selling away. Receipt of notification is not the same as authorization.
One of the features of a broker/dealer is that they sometimes maintain an inventory of securities, even when not in the role of market maker. If a broker/dealer has shares of a somewhat speculative, thinly traded stock in their inventory whose last reported trade was several days ago at $4 per share and the firm were to offer their shares at $10 per share, the NASAA Statement of Policy on Dishonest and Unethical Business Practices of Broker/Dealers and Agents might consider: A) this not prohibited because with thinly traded stocks, one expects there to be a wide spread. B) this may only be done if the broker/dealer makes adequate disclosure to clients who purchase the stock. C) this prohibited because the offering price does not bear a reasonable relationship to the current market. D) this prohibited because broker/dealers may not offer stock to the public from their own inventory.
Answer: C Yes, it is always possible that in just a couple of days, this company's stock may have increased by 250%, but there is nothing in the question to indicate that. Yes, thinly traded stocks tend to have wider spreads, but not like this.
Which of the following statements are TRUE of a discretionary account? It must be approved by a principal of the firm. It must be reviewed frequently. A discretionary order may be placed once the customer has placed a power of attorney in the mail. It must be approved by the SEC. A) I and III. B) II and IV. C) III and IV. D) I and II.
Answer: D A new discretionary account must first be approved by a principal, orders must be approved on the day of the trade, and the account must be reviewed frequently for suitability.
Under the NASAA Statement of Policy on Dishonest or Unethical Business Practices of Broker/Dealers and Agents, it would be considered a prohibited practice for a broker/dealer to: A) fail to maintain the required net capital. B) maintain an office in the state, but fail to register with the Administrator. C) inform customers that past performance is no guarantee of future results. D) have a history of repeatedly delaying the delivery of securities to its customers.
Answer: D Broker/dealers are obligated to make prompt delivery of securities to their clients. Failing to maintain the required net capital, or failing to register are violations of the law, not a prohibited business practice.
According to the Uniform Securities Act, market manipulation includes all of the following EXCEPT: A) pegging. B) buying and selling intentionally to show market activity. C) giving a false quote. D) buying on one exchange and selling on another.
Answer: D Buying on one exchange and selling on another is called arbitrage, not market manipulation, and it is an accepted business practice.
All of the following are prohibited sales practices EXCEPT: A) withholding a material fact from the buyer. B) buying and selling intentionally to create market activity. C) falsifying a quote. D) buying on one exchange and selling on another. Click for Answer and Explanation Answer: D Buying on one exchange and selling on another is the perfectly acceptable market practice known as arbitrage. Withholding material facts, buying and selling to show market activity, and falsifying quotes are all prohibited practices.
Answer: D Buying on one exchange and selling on another is the perfectly acceptable market practice known as arbitrage. Withholding material facts, buying and selling to show market activity, and falsifying quotes are all prohibited practices.
Under the USA, a guaranteed security is protected by someone other than the issuer against loss of all of these EXCEPT: A) interest on debt securities. B) dividends on equity securities. C) principal repayment at maturity on debt securities. D) principal on equity issues.
Answer: D Guarantees generally apply to income from the security (dividends or interest) and to payment of the principal amount at maturity. Third-party guarantees do not provide against market loss. Please note that capital gains are never included in this type of guarantee.
Under NASAA's Statement of Policy on Dishonest or Unethical Business Practices of Broker/Dealers and Agents, what factors are considered in determining whether excessive trading has occurred? The length of time the account has been opened. The frequency of trading. The amount of trading. The financial condition of the account and the financial resources and goals of the client. A) I, II, III and IV. B) I and II. C) III and IV. D) II, III, and IV.
Answer: D In determining whether excessive trading has occurred, consideration must be given to the amounts and frequency of trading in view of the financial resources, investment objectives, and character of the client's account. All factors must be considered together and not individually. Frequent trading and trading large amounts are not wrong in and of themselves; they are permitted if suitable for that particular customer. The length of time the account has been opened would not be factor.
Which of the following statements regarding matched orders is TRUE? A) Advisers should pursue matched orders because they mirror an investor's trading objectives and time horizon. B) Matched orders reflect the timing of capital gains to be offset by capital losses and are considered an effective and permissible tax minimization strategy. C) Matched orders are a prohibited practice because they entail allocation of IPO stock in proportion to the level of customer trading activity. D) Matched orders violate trading rules because they create the illusion of trading volume where such volume would not otherwise occur.
Answer: D Matched orders violate trading rules because they create the illusion of trading volume where such volume would not otherwise occur.
It would be considered a prohibited activity for an agent to engage in any of the following activities EXCEPT: A) failing to record exempt transactions on the broker/dealer's books and records. B) trading in the account of a conservative client exclusively in initial public offerings with proper trading authorization from the client. C) sharing in profits of an account as a reward for the agent's recommendations exceeding the S&P 500. D) executing a transaction in a nonexempt security in a discretionary account.
Answer: D Once a discretionary account has been properly documented, the agent handling the account can trade exempt and nonexempt securities. All transactions, no matter in exempt or nonexempt securities, must be recorded on the books of the broker/dealer. As a general rule, initial public offerings tend to be on the speculative side, suitable for aggressive, not conservative investors. Therefore, even with the client's authorization, this trading profile would be unsuitable and, as a result, a prohibited activity. . Sharing in profits of an account as a reward for exceeding the S&P 500 is prohibited under any circumstance. This is not the same as sharing in the profits of an account with consent of the client and the employing broker/dealer, as this is based on the performance of the agent's recommendations.
A customer in a low tax bracket is retired and living on a fixed income. An agent constructs a portfolio consisting of high-yield bonds and small-cap stocks for this customer. If this came to the attention of the Administrator, under the Uniform Securities Act, the Administrator would probably: A) force the agent to offer rescission. B) suspend the agent's license until the bonds mature. C) not take action against the agent. D) take action against the agent for selling unsuitable investments.
Answer: D Selling high-yield bonds, bonds with a speculative rating, would not be suitable for an investor with this profile. Nor would small-cap stocks since their risk level is certainly more than what this investor can accept. Rescission is only an option when a sale is made in violation of the act. No such violation is apparent here. If action was taken and a suitability violation was proven, revocation or suspension could not take place without a hearing.
When a broker/dealer engages in a customer transaction from its own account, which of the following statements are TRUE? Partners of the broker/dealer are trading in their personal accounts. The broker/dealer is trading from its inventory with customers. The broker/dealer must disclose its capacity as a principal in the transaction. The broker/dealer must disclose its capacity as agent in the transaction. A) I and III. B) I and IV. C) III and IV. D) II and III.
Answer: D The Uniform Securities Act defines a broker/dealer as a legal person (entity) engaging in the business of effecting securities transactions for the account of others or for its own account. In this context, trading for its own account means that the broker/dealer is trading from its inventory with customers. The broker/dealer has an ethical responsibility to disclose its capacity as a principal in the transaction. When trading for its own account, a broker/dealer is functioning as a principal or dealer. When trading for the accounts of others with no participation as a direct party to the trade, a broker/dealer functions in an agency capacity.
If a licensed agent believed that interest rates were about to fall and contacts all of her clients and suggests they purchase high quality debt securities with long-term maturities, this action: A) is in error as a drop in interest rates will cause bond prices to fall, leading to a loss in the client's accounts. B) is probably not in violation of any suitability standards as long as the bonds are of high quality. C) may be acting on material inside information. D) has probably violated the Uniform Securities Act's suitability standards.
If a licensed agent believed that interest rates were about to fall and contacts all of her clients and suggests they purchase high quality debt securities with long-term maturities, this action: A) is in error as a drop in interest rates will cause bond prices to fall, leading to a loss in the client's accounts. B) is probably not in violation of any suitability standards as long as the bonds are of high quality. C) may be acting on material inside information. D) has probably violated the Uniform Securities Act's suitability standards.
If a new customer will not state investment objectives and will not provide a financial statement, the agent may: A) sell only securities listed on a national exchange. B) solicit orders for any security without restrictions. C) accept unsolicited orders until the customer's suitability is determined. D) sell only stocks recommended by the broker/dealer.
If a new customer will not state investment objectives and will not provide a financial statement, the agent may: A) sell only securities listed on a national exchange. B) solicit orders for any security without restrictions. C) accept unsolicited orders until the customer's suitability is determined. D) sell only stocks recommended by the broker/dealer.
If the Administrator were examining the actions of a particular agent to determine whether the agent engaged in churning a client's account, focus would be placed upon the: A) amount of profits generated in the client's account. B) length of time the account had been opened. C) number of complaints received relating to that agent. D) client's objectives, financial resources, and the character of the account.
If the Administrator were examining the actions of a particular agent to determine whether the agent engaged in churning a client's account, focus would be placed upon the: A) amount of profits generated in the client's account. B) length of time the account had been opened. C) number of complaints received relating to that agent. D) client's objectives, financial resources, and the character of the account.
MaryBeth is an agent with QuickTrade Securities, a subsidiary of QuickLoan Bankcorp, a holding company that also owns QuickIssue Capital Markets, an underwriter specializing in bringing new issues to market. Under the NASAA Statement of Policy on Dishonest and Unethical Business Practices of Broker/Dealers and Agents, MaryBeth would be permitted to split commissions resulting from securities transactions with any of the following individuals EXCEPT A) an agent registered with QuickIssue Capital Markets B) the principal supervising her activities at QuickTrade Securities C) an agent properly registered with USATrade Securities D) another agent registered with QuickTrade Securities
MaryBeth is an agent with QuickTrade Securities, a subsidiary of QuickLoan Bankcorp, a holding company that also owns QuickIssue Capital Markets, an underwriter specializing in bringing new issues to market. Under the NASAA Statement of Policy on Dishonest and Unethical Business Practices of Broker/Dealers and Agents, MaryBeth would be permitted to split commissions resulting from securities transactions with any of the following individuals EXCEPT A) an agent registered with QuickIssue Capital Markets B) the principal supervising her activities at QuickTrade Securities C) an agent properly registered with USATrade Securities D) another agent registered with QuickTrade Securities