📖 Standard VI(C)：介绍费（Referral Fees）

1. Standard Text

Standard VI(C) — Referral Fees

Members and Candidates must disclose to their employer, clients, and prospective clients, as appropriate, any compensation, consideration, or benefit received from or paid to others for the recommendation of products or services.

2. Core Meaning

Bidirectional Disclosure Obligation for Referral Fees:

Receiving a referral fee → Must disclose to client/employer
Paying a referral fee → Must disclose to client/employer

In one sentence: Any monetary or benefit flow related to a recommendation must be transparent.

3. Types of Referral Fees

3.1 What You Must Disclose

3.2 What Does NOT Qualify as Referral Fees

• Normal salary and bonuses from the employer (unless tied to a specific third-party recommendation)
• Public promotional offers unrelated to a recommendation act
• Small, token gestures of thanks that do not affect objectivity (e.g., a lunch invitation — though disclosure is still advised)

4. Disclosure Requirements

4.1 To Whom to Disclose

4.2 What to Disclose

Must disclose:

1. Nature of the referral fee — cash or non-cash benefit
2. Amount or value — at minimum, an estimated range
3. Who is paying — the source of the referral fee
4. Relationship to the recommendation — fixed fee or percentage-based
5. Timing — one-off or ongoing income stream

4.3 Timing of Disclosure

Timeline:
    │
    ├──→ Disclose before (or at the time of) the recommendation
    │      Clients should know about your interest before they make their decision
    │
    └──→ For ongoing referral fee arrangements, periodically remind clients

5. Cross-References with Other Standards

6. Case Studies

Case 1: Attorney Referral Fee

Financial advisor A refers a client to attorney B for estate planning. Attorney B pays A a 10% commission. A does not disclose this to the client.

Violation: A received a referral fee but did not disclose it to the client. The client mistakenly believed A's referral was based purely on professional judgment.

Case 2: Fund Supermarket Kickbacks

A platform ranks recommendations based on "listing fees" paid by fund companies but does not disclose this arrangement to clients.

Violation: "Listing fees" are a variant of referral fees; without disclosure, clients believe the ranking is based on objective assessment.

Case 3: Cross-Referral Arrangement

Accountant C and financial advisor D agree to refer clients to each other, with no monetary payment involved.

Potentially compliant, but disclosure is recommended: Although no money changes hands, if the mutual referral motivation affects objectivity, the relationship should be disclosed. Best practice: inform clients of the cross-referral arrangement.

Case 4: Intra-Group Referral

A bank relationship manager recommends the bank's own trust services and receives an additional bonus for it.

Disclosure required: The extra bonus is tied to the referral act → the financial interest must be disclosed to the client.

7. Memory Aid

"If money or benefit flows from a referral, the flow must be shown."

Whether receiving or paying, any benefit flow arising from a recommendation must be made clear to clients and the employer.

8. Practice Questions

1. VI(C) requires referral fee disclosure primarily to:

A) Regulators only
B) Employer, clients, and prospective clients
C) Compliance department only
D) CFA Institute

2. A financial advisor refers a client to a tax consultant and receives a $2,000 referral fee. The advisor should:

A) Report to the employer only
B) Disclose this referral fee to the client before or at the time of the referral
C) No disclosure needed if the amount is small
D) Report to CFA Institute only

3. Regarding the relationship between VI(C) and IV(B):

A) They are unrelated
B) If referral fees come from a third party and are work-related, both VI(C) and IV(B) are triggered
C) VI(C) replaces IV(B)
D) Only one needs to be complied with

4. Which of the following most likely constitutes a "referral fee" requiring disclosure?

A) A quarterly bonus from the employer (based on overall performance)
B) A $5,000 travel package gifted by a fund company after recommending their fund to a client
C) A box of chocolates voluntarily given by a client
D) A free lunch during an industry conference

5. A platform ranks recommendations based on fees paid by fund companies without disclosing this to clients. This:

A) Is compliant — it is a business model
B) Is a violation — listing fees are a variant of referral fees/conflicts of interest and must be disclosed
C) Is compliant — as long as regulators do not object
D) Is a violation — but only of VI(A), not VI(C)

Answer Key

1. B — VI(C) explicitly requires disclosure to the employer, clients, and prospective clients.
2. B — Must be disclosed before or at the time of the referral to allow clients to make informed decisions.
3. B — Referral fees from third parties are subject to disclosure under both VI(C) and IV(B).
4. B — A $5,000 travel package is clearly a non-cash benefit obtained through a recommendation act.
5. B — "Listing fees" are a commercial variant of referral fees; non-disclosure = violation.

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