Rajat Sharma, CFA achieved superior returns as a portfolio manager when he was KJI Advisors. After leaving KJI, Sharma joined AER Ltd. In a presentation to AER clients, Sharma uses the returns he achieved at KJI, without clarifying that the returns were obtained during his employment at KJI. Has Sharma violated the Standards?

Explanation: It may be tempting to conclude that this is a Communication violation, but it is really Misrepresentation. The Communication Standard requires: 1. Disclose to clients and prospective clients the basic format and general principles of the investment processes used to analyze investments, select securities and construct portfolios, and must promptly disclose any changes that might materially affect those processes. 2. Use reasonable judgment in identifying which factors are important to their investment analyses, recommendations or actions, and include those factors in communications with clients and prospective clients. 3. Distinguish between fact and opinion in the presentation of investment analysis and recommendations. You can see none of the Communication requirements fit the situation described.