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Re: Notice of Proposed Conditional Exemptive Order Granting a Conditional Exemption from the Information Review Requirement of Amended Rule 15c2-11 (a)(1)(i) and the Recordkeeping Requirement of Amended Rule 15c2-11... (File No. S7-23-20)

This letter is submitted on behalf of the Federal Regulation of Securities Committee of the Business Law Section of the ABA in response to the request for comments by the SEC with respect to its SEC Release No. 34-90769.

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