18 Lisa Peterson, CFA, is a portfolio manager at GHI Investments (GHI). Peterson uses the software of AIQ, an external vendor. She recommends AIQ's software to her clients and receives a referral fee from AIQ when clients subscribe to the software. Peterson informs her employer and all clients about the arrangement with AIQ. Separately, GHI gives existing clients a small discount on the firm's service fees after referring new clients to GHI. Peterson informs all referred clients about this arrangement immediately after they sign GHI's service agreement.
Did Peterson's actions violate the Standard relating to referral fees?