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Given this, we do not see the need for mfda certs The workflows appear reasonable, but we note that centralizing and facilitating the distribution of ce activities to all ap’s via mfda certs, would set the mfda to become the de facto ce distributor for all registrants. Adding an additional system (such as mfda certs) to the model would add an administrative burden to firms like ours that already have developed tracking and reporting systems in place, including additional related labor costs.

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