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XI. Recidivism
The examination staff closely reviews the actions that advisers have taken to remedy the deficiencies cited during past examinations. Examiners have found instances where advisers have failed to correct violations cited during prior examinations, even after representing to the staff in writing that such violations would be corrected promptly. These violations may be subject to enforcement action, if appropriate.
XII. Inadequate Internal Control and Supervisory Procedures
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