The Commission had proposed to eliminate from Rule 17a 3 a definition of „associated person” and instead use the definition of „associated person” as defined in sections 3(a)(18) and 3(a)(21) of the Exchange Act. However, the statutory definition of „associated person of a broker or dealer” in section 3(a)(18) specifically excludes those persons whose functions are clerical or ministerial from the definition solely for purposes of section 15(b) of the Exchange Act. Current Rule 17a 3 excludes those persons from the recordkeeping requirements.

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