H.S. Dent Investment Management L.L.C., §5.H; Rule 109.6, 7/1/2002
§5.H exemption under former Rule 109.3 [now 109.6] not available for advice provided to registered investment advisers unless such investment advisors are also financial institutions or institutional investors otherwise covered by the rule.
The link address is: /committees/securities-law-committee/securities-law-committee-resources/no-action-letters/h-s-dent-investment-management-l-l-c-ss5-h-rule-109-6-7-1-1902.pdf/@@download/file