Alert January 15, 2013

SEC Staff Grants Two-Year Extension of No-Action Relief Permitting Broker-Dealers to Rely on Registered Advisers to Perform AML Customer Identification

The staff of the SEC’s Division of Trading and Markets issued a no-action letter to the Securities Industry and Financial Markets Association (SIFMA) that extends for two years relief granted by the staff in 2011 that allows broker-dealers to rely on registered investment advisers to satisfy the broker-dealers’ customer identification program (CIP) obligations for shared customers under certain conditions.  For a description of the 2011 relief, please see the January 25, 2011 Financial Services Alert.