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account statements Adopting Release advertisement adviser's Advisers Act Release advisory clients advisory contracts advisory fees advisory services affiliated annual review attorney-client privilege books and records broker-dealer brokerage Cambiar Cambiar Investors Chief Compliance Officer client assets client funds compliance policies compliance procedures compliance program Counsel Custody Rule DALBAR Director disclosure Division of Investment Exchange Commission firm firm's Form ADV fund's funds or securities hedge fund advisers Investment Advisers Act investment advisory Investment Management investors issues Munder Munder Capital Management mutual fund OCIE partial client list person policies and procedures Ponzi scheme pooled investment portfolio practice Practising Law Institute proposed satisfaction guarantee prospective clients proxy voting punj qualified custodian refund registered investment adviser regulatory request response risk SEC staff SEC's Section Securities and Exchange securities laws service providers spunj supra note TCW Advisers third party transactions violations