News & Analysis as of

Custody Rule Coronavirus/COVID-19

Dechert LLP

Upcoming Regulatory Initiatives Impacting Private Fund Managers - September 2022

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This latest edition of the regulatory initiatives paper sets out at a high level the core regulatory issues that are likely to impact private fund managers in the coming months, including an overview of the key actions needed...more

Foley & Lardner LLP

SEC Enforcement Actions Impacting Private Fund Advisers for Fiscal Year 2020

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On November 2, 2020, the SEC’s Division of Enforcement issued its 2020 Annual Report for the fiscal year ending September 30, 2020. While the Enforcement Division filed 405 standalone enforcement actions – the lowest total in...more

Vedder Price

Special Issue on COVID-19 Related Developments - Investment Services Regulatory Update - April 2020

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COVID-19 RELATED DEVELOPMENTS – SPECIAL REGULATORY UPDATE – New SEC Guidance on PPP Loans, Form ADV Brochure Delivery and the Custody Rule - On April 27, 2020, the staff of the Securities and Exchange Commission (the...more

Vedder Price

New SEC Guidance on PPP Loans, Form ADV Brochure Delivery and the Custody Rule

Vedder Price on

On April 27, 2020, the staff of the Securities and Exchange Commission (the “SEC”) updated its Division of Investment Management Coronavirus (COVID-19) Response FAQs and Staff Responses to Questions About the Custody Rule...more

Dechert LLP

NEWSFLASH: SEC IM Staff Updates Custody Rule FAQs to Address Issues Arising in Connection with Surprise Examinations and Certain...

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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

Akerman LLP

COVID-19 Impact on the Investment Management Industry

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As the outbreak of the coronavirus disease (COVID-19) spreads across the globe, its impact on markets, businesses and portfolios continues to grow. The challenges and opportunities COVID-19 presents to those in the investment...more

Morrison & Foerster LLP

SEC Responds To Advisers’ Questions Under Business Continuity Scenarios

Like all of us, the SEC and its staff are moving rapidly to address changes to normal procedures required in the face of COVID-19. In response to questions recently raised by the Investment Advisers Association (IAA) on...more

Foley Hoag LLP

New SEC FAQs Released in Response to COVID-19

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On March 16, 2020, in response to the COVID-19 outbreak, the United States Securities and Exchange Commission (“SEC”) Division of Investment Management updated their Frequently Asked Questions (“FAQs”) relating to Form ADV...more

Foley & Lardner LLP

Securities and Exchange Commission Relief for Investment Advisers to Mitigate Challenges Caused by the Coronavirus

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The Securities and Exchange Commission (SEC) has recognized that coronavirus disease 2019 (COVID-19) has caused, and may cause, disruptions that limit investment advisers’ access to facilities, personnel, and third party...more

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