Explanation

Max Ohn has violated the Standard relating to referral fees in two ways:

1. Failure to Disclose to Employer

Under Standard VI(C) - Referral Fees, members and candidates must disclose to their employer any compensation, consideration, or benefit received from or paid to others for the recommendation of products or services. This disclosure must be made in writing. Ohn's reasoning that the real estate agency doesn't compete with his firm and that the arrangement benefits his firm is irrelevant - disclosure to the employer is mandatory regardless of these factors.

2. Improper Timing of Client Disclosure

Ohn discloses the referral arrangement to clients after they become firm clients, which violates the requirement that disclosure must be made before entering into a formal client relationship. According to Standard VI(C), clients must be informed of any referral arrangement prior to the referral so they can make an informed decision about whether to use the referred service.

Key Requirements of Standard VI(C):

• To Employer: Written disclosure of all referral arrangements
• To Clients: Disclosure before the referral is made
• Nature of Disclosure: Must include the nature of the consideration or benefit

Correct Answer: C - Yes, by omitting disclosure of the arrangement to his firm and by disclosing the referral arrangement to referred clients after they become firm clients