To write or not to write? Referral fees

Do referral fees need to be disclosed in writing ? In topic test Sue Kim Case Scenario, the answer key says that they must be disclosed in writing, but the curriculum just requires ‘’disclosure”

Disclosure implies something to be written, at least from CFA Ethics perspective. *flies away*

Not sure about that. If that were the case, there would be no need to specify ”in writing” in so many cases.

Case in point: curriculum/ code requires disclosure of gifts for past performance. This disclosure can be done verbally.

I think:

All additional compensation agreements have to made in writing.

All referral fees have be notified in writing.

Disclose gifts for past performance - verbal is OK here.

If in doubt go for more conservative approach, that was my thumb rule

Referral fees - yes. must be disclosed in writing

Sorry… There is no explicit mention anywhere that it had to be in writing.

I don’t know… they don’t say it explicitly in the definition of the disclosure requirements, but in Example 2 (Disclosure of Interdepartmental Referral Arrangements) the final sentence reads: “The disclosure should include the nature and the value of the benefit and should be made in writing.”

Such a nuisance.