Under Rule 206 4-7 (which is part of the act of 1940), it is unlawful for an investment adviser registered with the SEC to provide investment advice unless the adviser has adopted and implemented written policies and procedures reasonably designed to prevent violation of the advisers act by the adviser or any of its supervised persons. The rule requires advisers to consider their fiduciary and regulatory obligations under the advisers act and to formalize policies and procedures to address them.
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