Belen Zapata, CFA, is the owner of Kawah Investments. Kawah promises investors returns of up to 12% per year by investing in non-investment-grade bonds and other fixed-income instruments. Due to unprecedented low bond market yields, Zapata fails to achieve the expected returns. No investments are made, and clients receive their original investment back. Under the CFA Institute Standards of Professional Conduct, Zapata most likely violated the standards because of the: