Kelley A. Howes

Kelley A. Howes

Morrison & Foerster LLP

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Latest Posts › Custody Rule


SEC Sanctions Adviser, Executives and CCO for Custody Rule Violation – Again

On November 19, 2015, the SEC sanctioned a registered investment adviser, its two owners, and a former chief compliance officer for violating the Advisers Act “custody rule” after previously settling similar charges and...more

11/23/2015 - Chief Compliance Officers Custody Rule Pooled Investment Vehicles Registered Investment Advisors SEC

SEC Targets More Firms for Custody Rule Violations

On October 28, 2013, the SEC sanctioned three registered investment advisers for, among other things, violating Rule 206(4)-2 under the Advisers Act (the “Custody Rule”). These settled actions, the subject of a special SEC...more

10/31/2013 - Chief Compliance Officers Custody Rule Customer Funds Enforcement Actions Investment Adviser Penalties SEC

SEC Staff: Private Stock Certificates May Not Be Subject to Custody Rule

In a recent IM Guidance Update, the SEC’s Division of Investment Management said that it would not object if registered investment advisers (RIAs) to certain private funds do not maintain “private stock certificates” with a...more

8/23/2013 - Custody Rule Investment Adviser SEC Stocks

Investment Management Legal + Regulatory Update -- May 2013

In This Issue: Regulatory Updates - SEC Allows Limited Use of Social Media for Public Disclosure; Federal Reserve Board Publishes a Final Rule Specifying when Nonbank Firms are “Predominantly Engaged in...more

5/17/2013 - Broker-Dealer Custody Rule ETFs Federal Reserve Final Rules Investment Management Nonbank Firms Pensions Public Disclosure SEC Social Media Startups

SEC Adviser Exams Find Widespread Violations of Custody Rule

The SEC’s Office of Compliance Inspections and Examinations reports finding widespread compliance deficiencies related to custody of securities. In its March 4, 2013 National Exam Program Risk Alert, OCIE said that...more

3/8/2013 - Audits Custody Rule Customer Funds Protection Investment Adviser Investors NEP SEC

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