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25 August 2017 Comment Letter

Comment Letter on Proposed Model Rule Amendment to the Unethical Business Practices of Investment Advisers, Investment Adviser Representatives and Federal Covered Advisers

Kurt Schacht, JD, CFA and Linda Rittenhouse, JD

CFA Institute recommends that NASAA deem accessing client accounts online with unique client identifying information inadvisable, rather an official “unethical business practice” in its model rule.

Comment Letter on Proposed Model Rule Amendment to the Unethical Business Practices of Investment Advisers, Investment Adviser Representatives and Federal Covered Advisers

View Comment Letter