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Dechert Comment Letter to SEC Regarding Standard of Conduct for Investment Advisers (PDF)
Dechert LLP 
[Opinion] Nov. 27, 2018
"[U]nless the standards provide appropriate flexibility to accommodate the vast diversity of advisers and clients, and allow for evolving and differing business models, they will harm advisers and clients, damage the industry, and stymie innovation. If the Commission decides to move forward with a final interpretation and does not withdraw the IA Proposal, we believe that the Commission must address a number of concerns."
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