Reported by Scott H. Moss, Robert A. Johnston Jr., Samantha Sigelakis-Minski, and Angenny M. Rosario Under the Notice of Proposed Rule Making (NPRM), Investment Advisers would be required to implement reasonable procedures to identify and verify the identity of their customers.3 The NPRM would define “account” as “any contractual or other business relationship between a person and an investment […]