On September 21, 2010, the SEC staff issued a no-action letter to BNY ConvergEx Group, LLC stating that a broker-dealer’s provision of research services to an institutional investment adviser would not establish an adviser-client relationship under the Advisers Act between the broker-dealer and the institutional investment adviser’s clients. According to BNY ConvergEx’s letter, many research broker-dealers have refused cash payments for their proprietary research from executing brokers because the investment adviser’s clients may be viewed as the research broker-dealer’s clients and, as a result, the principal transaction restrictions under the Advisers Act may apply.