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Custody Rule Guidance Update

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

Dechert LLP

SEC Staff Requests Comments on the Custody Rule: Non-DVP Trading and Digital Assets

Dechert LLP on

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

Orrick - On the Chain

The Beat Goes On: Division of Investment Management Seeks Input on the Impact of the Custody Rule on Digital Currency – and Vice...

Orrick - On the Chain on

As part of its ongoing examination of the Custody Rule, the SEC’s Division of Investment Management is seeking views from the securities industry members and the public on two issues regarding the Custody Rule: (1) the...more

Akin Gump Strauss Hauer & Feld LLP

Custody Concerns for Investment Advisers as Loan Agents

On December 20, 2018, the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (SEC) issued conditional no-action relief to Madison Capital Funding LLC (“Madison”), clarifying...more

Locke Lord LLP

SEC Staff Provides Guidance Regarding Inadvertent Custody by Investment Advisers

Locke Lord LLP on

Investment Advisers Act Rule 206(4) (the “Custody Rule”) is designed to protect client funds and securities from being lost, misused, or otherwise misappropriated by investment advisers. As such, the Custody Rule provides...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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