Answer: A) need not disclose that fact to the clients
Explanation: An investment adviser representative need not disclose the fact that he/she uses third-party research to formulate portfolio to the clients and the reason is this: It is not necessary to disclose what sources an investment adviser representative uses as the basis for portfolio recommendations, and thus is never in violation of his fiduciary responsibility. However, if the third-party research used is to be distributed to his clients, then, proper attribution is required.