Tom is a very successful investment advisor representative and has decided that he is going to hire another investment adviser to help him manage some of his client accounts. tom places about one third of his client accounts under the management of the new investment adviser and will share his advisor fee with the new investment manager. at the end of the year tom receives a complaint letter from one of his clients who was managed by the new investment adviser. the client is unsatisfied with the losses generated in her trust account. in this situation tom: