Covered persons on an SEC audit client (GQRMM – Policy 20.3.5) are permitted to have credit cards (including cash advance and overdraft protection arrangements tied to a credit card) from the SEC audit client, provided the aggregate current outstanding balance does not exceed US$10,000 at the payment due date. Balances are permitted to exceed this limit during the credit card cycle if the balances are reduced to $10,000 or less by the payment due date. Covered persons must aggregate credit card balances from the same SEC audit client (including private label credit cards issued by retailers such as department stores, airlines, etc.) when evaluating the $10,000 limitation and must also include the accounts of immediate family members.
Non-covered persons are permitted to hold credit cards from SEC audit clients without limitation.
I was in compliance with firm independence policies regarding credit cards during the Confirmation Period.
Covered persons on an SEC audit client (GQRMM – Policy 20.3.5) are permitted to have credit cards (including cash advance and overdraft protection arrangements tied to a credit card) from the SEC audit client, provided the aggregate current outstanding balance does not exceed US$10,000 at the payment due date. Balances are permitted to exceed this limit during the credit card cycle if the balances are reduced to $10,000 or less by the payment due date. Covered persons must aggregate credit card balances from the same SEC audit client (including private label credit cards issued by retailers such as department stores, airlines, etc.) when evaluating the $10,000 limitation and must also include the accounts of immediate family members.Non-covered persons are permitted to hold credit cards from SEC audit clients without limitation. I was in compliance with firm independence policies regarding credit cards during the Confirmation Period.
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