RegAlert2001-12-27
Added · Updated
SEC Division of Investment Management staff letter: Stephens Inc.
The SEC staff will not recommend enforcement action to the Commission under Section 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-3 if registered investment advisers pay cash solicitation fees to Stephens Inc. or its associated persons, despite prior Commission administrative orders and a court injunction that would otherwise disqualify them. This relief is conditional on Stephens complying with all applicable provisions of Rule 206(4)-3, ensuring advisers describe the arrangement in Form ADV, and discussing the disqualifying actions in written disclosures for ten years. The position applies only to the specific actions cited and does not waive other potential disqualifications under the Rule.
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Effective November 4, 2022, This Letter is Withdrawn. Please consult the following web page for more information: https://www.sec.gov/divisions/investment/im-modified-withdrawn-staff-statements .
Stephens Inc.
December 27, 2001
RESPONSE OF THE OFFICE OF CHIEF COUNSEL DIVISION OF INVESTMENT MANAGEMENT
Our Ref. No. 20011227103 Stephens Inc. File No. 801-15510 _____
We would not recommend enforcement action to the Commission under Section 206(4) of the Investment Advisers Act of 1940 ("Advisers Act") and Rule 206(4)-3 thereunder if any investment adviser that is required to be registered pursuant to Section 203 of the Advisers Act pays to Stephens Inc. ("Stephens"), a registered broker-dealer and investment adviser, or any of its associated persons, a cash fee for the solicitation of advisory clients in accordance with Rule 206(4)-3, 1 notwithstanding the existence of certain Commission administrative orders and a judgment of injunction from the U.S. District Court for the District of Columbia ("Actions"), each of which would otherwise preclude such an investment adviser from paying Stephens a solicitation fee. 2
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