The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement

"Reverse" Unibanco Arrangement "Reverse" Unibanco Arrangement: ✰ Adviser is organized in the United States ✰ Adviser is registered under the Advisers Act ❖ Foreign Participating Affiliate is the "contracting" entity with non-US clients ✰Foreign Participating Affiliate may or may not be registered under the Advisers Act ✰ US adviser assists in providing investment advice to the Foreign Participating Affiliate's non-US clients Question: Must the Foreign Participating Affiliate comply with Advisers Act when managing accounts of non-US clients? US-registered Adviser Foreign Participating Affiliate Investment Advice Morgan Lewis Non-US Client 47

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