During an examination of XYZ Investment Advisers, the SEC discovers that two of Adviser's portfolio managers have been engaged in frontrunning client accounts. Neither Compliance nor Senior Management had any knowledge of the scheme. If Adviser can show to the SEC's satisfaction that it had developed and enforced procedures reasonably designed to prevent frontrunning, Adviser will be able to claim that, despite the violation, Adviser has met its duty to?
1) assist the SEC.
2) maintain required books and records.
3) eliminate internal control deficiencies.
4) supervise.