Ethics Question in CFA Text

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The book is saying this is a violation of the misreprsentation standard I©. Wouldn’t this instead be a violation of the performance presentation standard III (D)?

Thanks

Misrepresentation covers “Members and candidates must not misrepresent any aspect of their practice, including (but not limited to) their qualifications or credentials, the qualifications or services provided by their firm, their performance record and the record of their firm, and the characteristics of an investment.” So it would be violated here. I would image this would also violate performance presentation but without looking, I seem to remember performance presentation had a lot to do with comparing to benchmarks? Maybe that is the difference here.