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Guidance Update Escrow Accounts

Proskauer Rose LLP

Regulation of Custodial Practices Under the Investment Advisers Act of 1940 Rule 206(4)-2: September 2020

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A. Adoption in 1962 - The SEC has regulated custodial practices of investment advisers since 1962, when it first adopted rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) under...more

Ballard Spahr LLP

HUD Revises Effective Date for Recent Updates to FHA Loan COVID-19 Guidance

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As previously reported, the U.S. Department of Housing and Urban Development (HUD) issued Mortgagee Letter 2020-23, dated July 28, 2020, to update COVID-19 national emergency guidance for FHA loans....more

Ballard Spahr LLP

HUD Updates COVID-19 Guidance for FHA Loans

Ballard Spahr LLP on

The U.S. Department of Housing and Urban Development (HUD) issued Mortgagee Letter 2020-23, dated July 28, 2020, to update COVID-19 national emergency guidance for FHA loans. The guidance addresses the verification of...more

Skadden, Arps, Slate, Meagher & Flom LLP

"SEC Provides Guidance on SPVs and Escrows Under the Custody Rule"

In June 2014, the Securities and Exchange Commission (the “SEC”) issued a guidance update (the “Update”) on the application of the custody rule of the Investment Advisers Act of 1940 (the “Custody Rule”) to special purpose...more

Goodwin

SEC Staff Provides Guidance on Custody Rule Compliance When Private Funds Use SPVs and Escrow Accounts

Goodwin on

The staff of the SEC’s Division of Investment Management issued IM Guidance Update No. 2014-7 (the “Guidance Update”) to provide guidance on how Rule 206(4)-2 under the Investment Advisers Act of 1940 (the “Custody Rule”)...more

Proskauer Rose LLP

New SEC Guidance on Application of Custody Rule to SPVs and Escrow Accounts

Proskauer Rose LLP on

The Securities and Exchange Commission (SEC) recently issued a guidance update (Update) on Rule 206(4)-2 of the Investment Advisers Act of 1940 (Custody Rule), which regulates the custody practices of registered investment...more

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