Michael L. Sherman

Michael L. Sherman

Dechert LLP

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SEC Grants Sub-Advisers No-Action Relief from Custody Rule Audit Requirements

A U.S. Securities and Exchange Commission (SEC) no-action letter issued on April 25, 2016 provides relief from the annual surprise audit requirement of the “Custody Rule” for a registered investment adviser (RIA)...more

5/5/2016 - Affiliates Audits Custody Rule Investment Adviser No-Action Letters Registered Investment Advisors SEC

SEC Division of Investment Management Provides Guidance Regarding the Custody Rule and Privately Offered Securities

The Division of Investment Management (Division) of the U.S. Securities and Exchange Commission (SEC) recently posted an IM Guidance Update that expands the applicability of an exception from the Custody Rule (as defined...more

8/28/2013 - Custody Rule GAAP Investment Advisers Act of 1940 Investment Company Act of 1940 Investment Management Pooled Investment Vehicles Private Offerings SEC

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