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News October 21, 2019 Issue

Adviser Settles Solicitor Rule Charges with SEC Following Two Examinations

Advisory firms that rely on a no-action letter to support their business practices should make sure that their interpretation of that letter is correct especially when those business practices are ones the SEC pays particular attention to, like compliance with Rule 206(4)-3, the Solicitor Rule. An advisory firm that relied on such a letter despite concerns raised by examiners recently learned this lesson.

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