Anne Franklin, CFA, is an analyst who covers technology stocks for Medallion Investments. Franklin frequently meets with company management and makes site visits to company facilities. Cynthia Lucas, chief technology officer for Level Tech, tells several analysts, including Franklin, during a conference call that overseas shipments of the company's important new product are going to be delayed due to manufacturing defects, which she expects are correctable. This information has not been released in any other format. Medallion manages discretionary accounts for Lucas and Franklin. Subsequent to her meeting, Franklin sends a note to Medallion's investment personnel telling them to "sell the stock in all client accounts," as the shipment information is significant and contrary to recent earnings guidance from the company. Franklin's use of the information received from Lucas:

A.Violates the Code and Standards,as Franklin received material nonpublic information that should not have been acted upon.

B.Violates the Code and Standards,since she directed the sale in all client accounts instead of acting in the best interests of her own clients.

C.Does not violate the Code and Standards,as Franklin was adhering to her fiduciary duty to Medallion's clients by sharing the information and recommending a "Sell."