RegAlert2003-10-31
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SEC Division of Investment Management staff letter: U.S. Bancorp Piper Jaffray Inc.
The staff will not recommend enforcement action under Section 206(4) of the Investment Advisers Act and Rule 206(4)-3 if a registered investment adviser pays U.S. Bancorp Piper Jaffray Inc. or its associated persons a cash fee for soliciting advisory clients, despite a Final Judgment from the United States District Court for the Southern District of New York that would otherwise preclude such payments. This relief is conditioned on Piper Jaffray complying with the Final Judgment, including the payment of disgorgement, pre-judgment interest, civil or administrative penalties, and fines. Additionally, Piper Jaffray must disclose the Final Judgment in a written document delivered to each solicited person not less than 48 hours before contract entry, or at the time of entry if the person has a 5-business-day right to terminate without penalty, for ten years from the date of the Final Judgment.
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Effective November 4, 2022, This Letter is Withdrawn. Please consult the following web page for more information: https://www.sec.gov/divisions/investment/im-modified-withdrawn-staff-statements .
U.S. Bancorp Piper Jaffray Inc.
October 31, 2003
RESPONSE OF THE OFFICE OF CHIEF COUNSEL
IM Ref. No. 200342891 U.S. Bancorp Piper Jaffray Inc.
DIVISION OF INVESTMENT MANAGEMENT
File No. 8-15204
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 U.S. Bancorp Piper Jaffray Inc. ("Piper Jaffray"), a registered broker-dealer and investment adviser, or any of Piper Jaffray's associated persons, as defined in Section 202(a)(17) of the Advisers Act, a cash fee, directly or indirectly, for the solicitation of advisory clients in accordance with Rule 206(4)-3, 1 notwithstanding a judgment of injunction from the United States District Court for the Southern District of New York (the "Final Judgment") that otherwise would preclude such an investment adviser from paying Piper Jaffray a solicitation fee. 2
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