📖 Standard VI(C)：介绍费 实际场景应用

1. VI(C) Quick Recap

Core: Any compensation or benefit related to a recommendation must be disclosed to clients and the employer.

2. Practical Scenario Deep Dives

Scenario 1: Financial Advisor vs. Insurance Agent

Manager Li is an independent financial advisor. He recommends an insurance
product to a client. The insurance company pays him 30% of the first-year
premium as commission.

Question: How should Manager Li handle this?

Bonus point: If lower-premium products exist on the market (with low or no commission), inform the client about cheaper alternatives.

Scenario 2: Sell-Side Analyst's "Soft" Referral Fee

Analyst Zhang works at a brokerage. A listed company invites him to an
"analyst research tour" — first-class flights + five-star hotel + golf.

Analyst Zhang subsequently publishes a positive research report on the company.

Key distinction: - If the company explicitly says: "Write a positive report and we'll treat you to a trip" → VI(C) referral fee - If the company's regular IR activity but the luxury level is excessive → I(B) + VI(A)

Scenario 3: Platform Economy Referral Fees

An online investment platform recommends financial products to users.
The ranking algorithm places products with "promotion fees" at the top.
The platform mentions this only in a footnote on page 37 of the user agreement.

Compliant approach: - Label "Promoted" or "Ad" above the recommended results - Clear conflict-of-interest statement in plain language - Offer two views: "Sorted by referral fee" and "Sorted by objective criteria"

Scenario 4: Cross-Border Referral Fees

Manager Wang is licensed in Hong Kong and recommends a US fund to a
Singapore-based client. The fund pays referral fees through a Bermuda entity.

One line: Cross-border does not change the disclosure obligation — it only adds complexity to manage.

Scenario 5: Intra-Group Referral Fees

A bank relationship manager recommends the group's asset management service.
The manager receives an additional bonus (directly tied to the referral).
The client only knows it is "the same bank's service."

Best practice: Tell the client: "I will receive additional compensation for recommending this service, but I also believe it suits you, for the following reasons..." (give objective reasons)

3. Quick Reference Table

4. Practice Questions

1. Which approach best satisfies VI(C)'s disclosure requirements for platform product recommendations?

A) Mention in the user agreement
B) Label "Promoted" clearly next to recommended results
C) Disclose only when regulators require
D) Inform via customer service phone call

2. An analyst is invited on a company "research tour" (first-class flights + five-star hotel). The best approach is:

A) Accept, then disclose in the research report
B) Decline the excessive portion (pay out of pocket for the amount exceeding reasonable limits) and maintain independence
C) Accept, but delay the research report
D) Accept everything — it is industry practice

3. Disclosure obligations for cross-border referral fees (involving multiple jurisdictions):

A) May be reduced due to jurisdictional differences
B) Are unchanged regardless of jurisdictional complexity — VI(C) disclosure obligations remain
C) Only required in the payer's jurisdiction
D) Only required above a certain monetary threshold

4. A bank relationship manager receives an extra bonus for recommending an intra-group service. The most important thing to say when disclosing to the client is:

A) "This is our group's service"
B) "I will receive additional compensation for this recommendation"
C) "You can buy it elsewhere too"
D) "This service is quite good"

5. VI(C)'s "referral fee" includes:

A) Cash payments only
B) Any compensation, consideration, or benefit received or paid as a result of a recommendation, including non-cash
C) Only payments exceeding $1,000
D) Only payments made directly to individuals

Answer Key

1. B — "Prominent" is a shared requirement of VI(A) + VI(C); a clear label next to recommended results is best practice.
2. B — Excessive hospitality compromises independence. Best practice is to decline the portion beyond reasonable limits (pay the difference out of pocket).
3. B — CFA Code disclosure obligations do not change due to jurisdictional complexity.
4. B — The core message is disclosing the financial interest. "I will receive additional compensation for this recommendation" goes straight to the point.
5. B — VI(C) covers any form of compensation or benefit, not limited to cash.

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