ken kawasaki, cfa, shares a building with a number of other professionals who are also involved in the investment management business. kawasaki makes arrangements with several of these professionals, including accountants and lawyers, to refer clients to each other. an informal score is kept on the expectation the referrals will equal out over time, eliminating the need for any cash payments. kawasaki never mentions this arrangement to clients or prospective clients. does kawasaki's agreement with the other building occupants most likely violate any cfa institute standards of professional conduct?