Max Ohn, CFA, works as a client advisor for a small firm. He has established a referral program with a real estate agency. Ohn refers clients to the real estate agency and the real estate agency refers clients to Ohn. Because the real estate agency does not compete with Ohn's employer and because the arrangement benefits Ohn's firm, he omits disclosure of the arrangement to his firm. Ohn diligently discloses the referral arrangement to all referred clients after they become firm clients. Has Ohn most likely violated the Standard relating to referral fees?