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EXCHANGE SERVICES, INC. v. S.E.C.

No. 85-1920.

797 F.2d 188 (1986)

EXCHANGE SERVICES, INC., Petitioner, v. SECURITIES AND EXCHANGE COMMISSION, Respondent.

United States Court of Appeals, Fourth Circuit.

Decided August 7, 1986.

Attorney(s) appearing for the Case

Dennis M. Ryan (Karen A. Gould; Crews, Hancock & Dunn on brief), for petitioner.

Richard A. Kirby, Asst. Gen. Counsel, S.E.C. (Daniel L. Goelzer, Gen. Counsel; S.E.C. on brief), for respondent.

Before WINTER, Chief Judge, and MURNAGHAN and ERVIN, Circuit Judges.

ERVIN, Circuit Judge:

Exchange Services, Inc. petitions this court to reverse the Securities and Exchange Commission (SEC) order upholding the decision of the National Association of Securities Dealers, Inc. (NASD) that certain personnel of Exchange Services must register as General Securities Representatives. Specifically, Exchange Services claims that the personnel perform only clerical or ministerial functions and thus should be exempt from registration. Exchange...

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