Suzanna Bermi, CFA, manages portfolios for retail clients. A friend asks her if Bermi can provide investment advice in Bermi's spare time. The friend offers a donation to Bermi's favorite charity in exchange for Bermi's advice. Bermi accepts the offer and starts providing investment advice to her friend immediately after sending an email to her firm's compliance department about the arrangement, including the fact that she receives no cash payments from her friend. Has Bermi most likely violated the Standards?