17 Alina Sokolova, CFA, has been an advisor at BT Investments (BTI) for the past seven years. She has disclosed her private holdings twice since she joined BTI. Sokolova allocates shares of a highly anticipated IPO to her clients on a pro-rata order basis. One of these clients is her sister, who is a regular fee-paying client of BTI.

Are Sokolova's actions consistent with the Standard relating to priority of transactions?