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If my firm qualifies for the enhanced supervisory requirements, can we take any steps to avoid adopting them?

Once your firm meets the enhanced supervisory criteria, it must adopt the requirements unless it files a petition for a waiver with the Telemarketing Procedures Waiver Committee and the Committee grants your firm's waiver request. In addition, changing the firm's personnel composition after it meets the criteria won't affect your firm's qualification status, so you cannot avoid it by terminating an employee who was included in the count of APs or principals who were previously employed by a Disciplined Firm. 

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