News & Analysis as of

Recordkeeping Requirements Custodians

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes Expansion of Custody Rule Safeguards for Investment Advisers | Insights

On February 15, 2023, the Securities and Exchange Commission (SEC) proposed new rules and amendments (Proposal) to Rule 206(4)-2 (Custody Rule) under the Investment Advisers Act of 1940 (Advisers Act)....more

Womble Bond Dickinson

Addressing Government Subpoenas

Womble Bond Dickinson on

Subpoenas from the government can often be viewed as unwelcome intrusions into the business of a passive custodian and its accountholders. With a few fundamentals in place, though, custodians can use subpoenas as an...more

Morrison & Foerster LLP

The SEC Adopts Amendments to Form ADV and Recordkeeping Rule: Advisers Now Required to Disclose Information About Separately...

The Securities and Exchange Commission (SEC) recently amended Form ADV to require investment advisers to disclose more information about their separately managed account business, aggregate data related to the use of...more

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