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sd-10-EFTA01372444Dept. of Justice

EFTA Document EFTA01372444

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6. Do you control or are you controlled by the related person? 7. Are you and the related person under common control? Yes No tr; r. r 8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients? r (b) If you are registering or registered with the SEC and you have answered "yes/' to question 8.(a) above, have you overcome the r r presumption that you are not operationally independent (pursuant to rule 206(4)-2

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Dept. of Justice
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sd-10-EFTA01372444
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