A registered investment adviser (RIA) that has “custody” of client funds or securities must comply with the provisions of Rule 206(4)-2 under the Investment Advisers Act of 1940 (Rule), including those related to the use of a...more
4/3/2020
/ Coronavirus/COVID-19 ,
Custodian of Records ,
Custody Rule ,
Division of Investment Management ,
Filing Requirements ,
Form ADV ,
Investment Advisers Act of 1940 ,
Private Offerings ,
Registered Investment Advisors ,
Relief Measures ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Verification Requirements
Through a March 12, 2019 letter (Letter), Paul Cellupica, Deputy Director and Chief Counsel of the SEC’s Division of Investment Management, on behalf of the Division’s staff invited industry engagement and sought information...more
3/23/2019
/ Blockchain ,
Comment Period ,
Custody Rule ,
Digital Assets ,
Distributed Ledger Technology (DLT) ,
Guidance Update ,
Investment Adviser ,
Investment Company Act of 1940 ,
Non-DVP ,
Proposed Rules ,
Public Comment ,
Securities and Exchange Commission (SEC)
The staff of the Division of Investment Management (Staff) of the U.S. Securities and Exchange Commission (SEC) released three related matters of guidance on February 21, 2017, which provide additional clarity to...more
The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) issued a National Exam Program Risk Alert on February 7, 2017 (Risk Alert), highlighting the “five compliance...more
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
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