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Murdoch is founder, president, and head portfolio manager of IOM Capital Management (IOM), an investment adviser providing investment advice to four affiliated hedge funds as well as separate client accounts. IOM accumulates and uses soft dollar credits primarily at a single broker/dealer through equity and options trading for the IOM funds and individual client accounts. IOM discloses allowable uses of soft dollars through its regulatory filings and offering memoranda for IOM funds. The disclosures provide that soft dollars may be used for "overhead expenses," including "office services, equipment, and supplies." IOM rents a portion of Murdoch's personal residence to conduct its business. IOM pays $6,000 in rent to a company Murdoch owns, which, in turn, pays $5,855 to a local bank to cover the monthly mortgage payment for the property. Eventually, IOM and Murdoch request that the broker use soft dollars to make the rental payment. Once the broker starts paying rent using soft dollars, Murdoch raises the rent first to $10,000 per month and then to $15,000 per month.
Required:
Considering CFA Ethical Standards I through Standards IV, which of these, if any, may Murdoch be violating? What are Murdock's ethical responsibilities to clients?
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