SEC Division of Trading and Markets Issues No-Action Relief Regarding Broker-Dealer Customer Identification Rule

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 from the date of this letter (January 11, 2013).

Click here to view letter in full (links externally to SEC website).See also: Incoming Letter.For a general discussion of Customer Identification Programs, seeSection III of Anti-Money Laundering Regulation for Financial Institutions.