Who says Standard VI© doesn’t need to be in writing? I see that no-where in the text. The text simply omits that part, but in their example it does say writing should be done.
According to the Standard VI©- Referral Fee examples, it says should be made in writing (page 162):
Example 2 (Disclosure of Interdepartmental Referral Arrangements): James Handley works for the trust department of Central Trust Bank. He receives compensation for each referral he makes to Central Trust’s brokerage department and personal financial management department that results in a sale. He refers several of his clients to the personal financial management department but does not disclose the arrangement within Central Trust to his clients.
Comment: Handley has violated Standard VI© by not disclosing the referral arrangement at Central Trust Bank to his clients. Standard VI© does not distinguish between referral payments paid by a third party for referring clients to the third party and internal payments paid within the firm to attract new business to a subsidiary. Members and candidates must disclose all such referral fees. Therefore, Handley is required to disclose, at the time of referral, any referral fee agreement in place among Central Trust Bank’s departments. The disclosure should include the nature and the value of the benefit and should be made in writing.
Also, AnalystPrep says so too… They must be right:
Appropriate disclosure means communicating before an investment professional enters into a contract with a client or a prospective client. The reporting of referral fees include type (i.e. flat fee, percentage of business), as well as estimate value. This should be done in writing , with both parties signing a written agreement.