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Is a registered investment adviser firm with only one investment adviser representative and no other employees required to maintain written supervisory and compliance policies and procedures?

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If your investment adviser is registered with the SEC or with a state securities regulator that requires written supervisory and compliance policies and procedures, your investment adviser is required to maintain such policies and procedures regardless of the number of employees or investment adviser representatives, if any, affiliated with the investment adviser. However, securities regulators have stated that these policies and procedures need to be written to cover the compliance considerations relevant to the operations of each particular registered investment adviser. It is expected that most smaller-sized registered investment advisers without conflicting business interests could utilize much simpler supervisory and compliance policies and procedures than larger-sized registered investment advisers that may have multiple conflicts of interest.

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