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Can someone who is an advisory client of an adviser act as an independent representative for other clients of that adviser?

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Can someone who is an advisory client of an adviser act as an independent representative for other clients of that adviser?

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Yes, if it meets the tests for independence set out in the rule. If the client relationship is a “material business relationship” (or the person has another material business relationship) with the advisory firm, the person will not meet the tests for independence.

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