USA Asset Management

You are a financial services professional who owns a dually registered firm with investment advisory and broker-dealer divisions.  One of your financial planning professional employees, in her capacity as a registered representative, referred clients to the investment advisory division of your firm. The financial planning employee did not disclose to clients that: 1) the divisions were related and that the clients could use investment advisory services from other firms; and 2) the financial planning professional had a conflict of interest in referring clients to the investment advisory division because she stood to obtain additional compensation through the firm's receipt of investment advisory fees. Is this a conflict of interest?  And, if so, what, when and how should she have disclosed it and then documented the disclosure?

This should be 2 pages in length.