Section 206(1) and (2) make it unlawful for any adviser, registered or not, to use the mails or interstate commerce to use any scheme or device to defraud a client or a prospective one, or to engage in a transaction, practice or course of business that operates as a fraud or deceit on them. Section 206(2) carries no scienter requirement; negligence is enough. The Supreme Court read these paragraphs in 1963 as imposing fiduciary duties: utmost good faith and complete, candid disclosure of every material fact, which is the foundation of the interpretation in domain 6. Section 208(d) extends the prohibition to indirect conduct through others.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.