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SEC No-Action Letter In a letter to SIFMA, the SEC Division of Market Regulation extended, with modifications, relief previously granted under Exchange Act Rule 17a-8 for broker-dealers to rely upon registered investment advisers to perform some or all of its Customer Identification Program obligations. Among other things, the new letter allows a broker-dealer to rely on an adviser when such reliance is "reasonable under the circumstances." The letter specifies that reasonable reliance requires a BD to undertake "appropriate due diligence" commensurate with the adviser's anti-money laundering

The Division of Trading and Markets has issued no-action relief stating that it will not recommend enforcement action under Exchange Act Rule 17a-8 ("Financial Recordkeeping and Reporting of Currency and Foreign Transactions") if a broker-dealer relies on a registered investment adviser to perform some or all of its customer identification program ("CIP") obligations. The letter extends a 2011 no-action position, which is substantially similar to previous no-action positions taken in 2004. Expiry Date : This letter extends the no-action position in the 2011 Letter for an additional 2 years

The NFA released July 2013 revisions to the Financial Requirements Section 16 and the related interpretive notice regarding cleared swaps customer collateral accounts. These updates are available in five appendices of policies that include: Compliance with theExchange Act Rule 15c3-1: the calculation of haircut charges on securities; additionally, charges on the more common securities are reviewed: government securities and Canadian debt obligations, municipal securities, other municipal securities, money market funds, commercial paper, bankers' acceptances and certificates of deposit, non

The SEC extended previous no-action relief provided to broker-dealers in 2013 under Exchange Act Rule 17a-8 ("Financial Recordkeeping and Reporting of Currency and Foreign Transactions") if a broker-dealer relies on a registered investment adviser to perform some or all of its customer identification program obligations. In February 2004 , the SEC Division of Trading and Markets (the "Division"), in consultation with the Financial Crimes Enforcement Network, issued a letter stating it would not recommend enforcement action to the SEC if a broker-dealer treated a registered investment adviser