Why this is not a violation here?

CFA Level III
#1

Later that day, Mutini scrutinizes Rayne’s marketing material with Rayne’s most successful sales agent, Tom Okello, another CFA charterholder. They are preparing for a sales meeting to introduce OAM products to a potential client. Mutini notices that Rayne’s responsibility to uphold the Code and Standards is not mentioned anywhere in the marketing material. Neither does the material mention that some of Rayne’s employees are CFA charterholders. Mutini also notices that Okello does not use the CFA designation on his business card. When Mutini asks him why, he responds, “If I use it, people will think I have a duty to Rayne’s clients. I do not have a duty to clients because stockbrokers in Uganda are not required to uphold a fiduciary duty. I do not want to mislead our clients by using the CFA designation.”

Given Okello’s comment regarding his reason for not using the CFA designation, he will most likely violate which of the following CFA Institute Standards of Professional Conduct?

  1. Misrepresentation, why this is not a violation here?
  2. Duties to Clients
#2

Misrepresentation is Standard I (C). Standard I is about professionalism.In the case, compared to Standard I: Professionalism, he is absolutely violate the Standard III: Duties to clients by not having duties to Rayne’s clients which he should has asked by CFA institution.

Also, he might violate Standard I(A): knowledge of the law by obeying the Uganda law rather than the CFA Standards and Codes, which is more stricter. But not the I(C): misrepresentation, which is relating to investment analysis, recommendations, actions, or other professional activities.