64 Jack Mackenzie, CFA, is an investment advisor. He receives referral fees when he refers clients to an estate planning lawyer. In turn, Mackenzie pays referral fees when he receives client referrals from an insurance broker. He discloses the details of both of these referral arrangements, including fees, to his employer and clients. Mackenzie discloses this information to his clients before entry into formal service agreements with them.

Does Mackenzie's actions violate the Standard related to referral fees?