The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement

"Classic" Unibanco Arrangement "Classic" Unibanco Arrangement: ✰ Adviser is organized in the United States Adviser is registered under the Advisers Act Adviser is the "contracting" entity with clients ✰Foreign Participating Affiliate assists in providing investment advice to the registered adviser's clients Question: Must the foreign Participating Affiliate be registered under the Advisers Act? US-registered Adviser Client Foreign Participating Affiliate Morgan Lewis Investment Advice 46

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