Answer: d. a misrepresentation of a fact knowing it is falso
Step-by-step explanation:
Reliance that gives rise to liability for fraud requires intentional misrepresentation, that is a misrepresentation of a fact knowing that it is false. If Ness, the broker intentionally misled Ollie and advised Ollie to buy Penny stock shares based on Ness's that the stock price will rise Ness will be charged with fraud.