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Does someone who is reviewing a producing manager under the limited size and resources exception have to be a principal?

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Does someone who is reviewing a producing manager under the limited size and resources exception have to be a principal?

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Yes. If the firm is so limited in size and resources that there is no qualified person senior to, or otherwise independent of, the producing manager to conduct the producing manager reviews, the firm may rely on Rule 3012’s limited size and resources exception and have the reviews conducted by a principal who is sufficiently knowledgeable of the firm’s SCPs.

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