| 1. | In addition to all other requirements in the Regulations and Rulebooks, VASPs providing Advisory Services shall establish, implement and enforce appropriate written internal policies and procedures relating to the following—
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| | a. | how they ensure the independent basis of their advice; |
| | b. | how they ensure all Staff providing advice are sufficiently competent in accordance with Rule II.B.1 of this Advisory Services Rulebook; and |
| | c. | such other policies and procedures as VARA may require from time to time.
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2.
| VASPs providing Advisory Services shall assess and, in any case, at least yearly review the effectiveness of their policies and procedures and take appropriate measures to address any deficiencies.
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