A client, Elara Vance, files a formal complaint against Sterling Futures Inc. and one of its account representatives, Kenji Tanaka, alleging a breach of fiduciary duty related to unauthorized trading and excessive margin calls in her futures account. Elara claims that Kenji executed trades without her consent and failed to adequately explain the risks associated with the high leverage used in her account, leading to significant financial losses. Sterling Futures\' compliance department initiates a preliminary review, primarily relying on Kenji\'s assertion that all trades were discussed with Elara and that she acknowledged the risks involved. The compliance department, citing Kenji\'s good standing within the firm and the lack of immediate contradictory evidence, decides to close the case without further investigation. Which of the following actions would MOST likely be considered a violation of CIRO regulations and established precedents concerning client complaints and fiduciary duty, particularly in light of the principles highlighted in the Varcoe case?