... Management (IM) issued three separate forms of guidance describing certain circumstances in which SEC-registered investment advisers (RIAs) may have custody of client assets for purposes of Advisers Act Rule 206(4)-2 (Custody Rule). The additional guidance includes an IM Guidance Update, an SEC staff...

... in deficiency letters sent to investment advisers after the completion of an OCIE examination. Design/methodology/approach Discusses deficiencies noted by the OCIE relating to the Compliance Rule, required regulatory filings, the Custody Rule, the Code of Ethics Rule, and the Books and Records Rule...

...Matthew T. Wirig; Kate S. Poorbaugh Purpose To summarize guidance from the Securities and Exchange Commission’s (“SEC”) Division of Investment Management regarding Rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940. Design/methodology/approach This article summarizes...

... be contacted at: michael.mcgrath@klgates.com © Authors 2015 Swaps Alternative mutual funds Alternative strategies Custody rule OCIE examination priorities SEC enforcement On February 12, 2015, the Securities and Exchange Commission (“SEC”) brought and settled charges against...