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According addition address changes adviser's Advisers Act advisory amended rule annual Arthur Levitt broker broker-dealer Butowsky CFTC clients costs Counsel custodian custody disclose disclosure e-mail EDGAR Editor electronic employee ERISA euro Exchange Commission exemptive federal fees filers firms Form fund directors fund's board independent directors index fund institutional Internet investment adviser Investment Company Act Investment Company Institute Investment Management investors IPOs issuer issues Jonathan Katz Kirkpatrick & Lockhart letter Levitt Lockhart Ronald H Manager's Compliance Guide material ment Monetta Money Manager's Compliance mutual fund NASAA NASD NASDR Neuberger Berman no-action OppenheimerFunds Partner percent performance person plaintiff portfolio prohibited proposed rule prospectus proxy Regulation release repo SEC staff Section Securities and Exchange Senior Vice President shareholders shares sion soft dollar statement subscription Thompson Publishing Group tion trading transactions vestment viser