Client level segregation prohibits offering both advisory and distribution services to the same client, requiring group and family separation. Regulation 22 requires strict client level segregation between advisory and distribution services: individual advisers and their families are barred from providing distribution to advised clients, non-individual advisers must segregate services at group level so the same client cannot receive both advisory and distribution services, with a client being exclusively advisory or distribution at group level; non-individual advisers must maintain an arm's length relationship by providing advisory services through a separately identifiable department or division, and compliance and monitoring must follow Board guidelines.
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Provisions expressly mentioned in the judgment/order text.
Client level segregation prohibits offering both advisory and distribution services to the same client, requiring group and family separation.
Regulation 22 requires strict client level segregation between advisory and distribution services: individual advisers and their families are barred from providing distribution to advised clients, non-individual advisers must segregate services at group level so the same client cannot receive both advisory and distribution services, with a client being exclusively advisory or distribution at group level; non-individual advisers must maintain an arm's length relationship by providing advisory services through a separately identifiable department or division, and compliance and monitoring must follow Board guidelines.
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