Application No. D-12122, Comment 03, Steptoe, 05142026

Summary: Goldman Sachs supports the Department's proposal to simplify the exemption but requests specific modifications to reduce the number of required audits and broaden the definition of "Goldman Affiliated QPAMs." They argue that three existing audits are sufficient to demonstrate compliance and that the proposed definition of affiliates should include all current and future entities rather than just a specific list.