EFTA Document EFTA01372454

8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients? C C. (b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the r r presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise examination for your clients' funds or securities that a