I read in part of the pages and pages of discussion in the commentary sections of the final rules and it states that P&P's must be in place before you register anyone. I know alot of folks contended that the P&P's should have been in place by 10-1, but the above statement says otherwise to me.
Once the register opens to FI's and it's announced, you have 180 days to register. From the way I read it, so long as you have your P&P's in place before you register and register by the 180th day, you should be within the requirements.
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My opinion only. Not legal advice.
Say you'll haunt me - Stone Sour