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I remember I chose 5 as the answer.

IF the firm has historical data of 12 years, it still could claim compliance of 5 years provided it explains the reason for the 7 non compliance data. Going forward, the firm is obliged to claim compliance up to 10 years. After 10 years, it's a moving quantuam of a decade. The firm does not need to show 12 years of compliance.

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