Jim allows his sales associates to create their own marketing materials and doesn't review those posts. One of his sales associates has placed an ad that has potentially violated Fair Housing. Jim:

A. Is not responsible as his sales associate is an independent contractor
B. Could be as liable as his sales associate for the ad
C. Is not liable because he doesn't have a policy manual, so he has safe harbor
D. Needs to put up a Fair Housing Poster in the office before any investigation ensues