Discretionary vs Non-Discretionary accounts

So, in one of the practice problems we read the following:
“From time to time, PIA receives initial public offering (IPO) allocations from FTI. Danko allocates these IPOs to those discretionary accounts that normally participate in IPOs. If the IPO is oversubscribed, he excludes his wife’s discretionary non-fee-paying account so that he is not accused of bias when allocating the oversubscribed IPOs.”

My questions are:

  1. Is there a requirement to give Non-Discretionary accounts equal opportunity (under fair dealing standard) to participate in IPO? Or is Danko in violation of Fair Dealing?
  2. I guess Danko must exclude wife’s account, but who besides wife, can be also considered as beneficial owner too? Children? Father and Mother?