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  • An investment adviser does not have an oversight process, other than that performed by the portfolio manager responsible for managing an account, to determine whether risks taken in managing client portfolios are consistent with each client's stated investment objectives and/or to measure and evaluate each client's risk tolerance.
  • * * * * *

    We hope that this letter will assist investment advisory personnel in reviewing their firm's compliance, supervisory and internal control procedures, and foster compliance with the Advisers Act.

    Sincerely,

    Lori A. Richards
    Director


    Footnotes

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