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Recent Staff Guidance on the Custody Rule under the Investment Advisers Act of 1940  

Author:  Christopher S. Petito.

Source: Volume 51, Number 03, February 1 2018 , pp.36-41(6)

Review of Securities & Commodities Regulation

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SEC staff guidance issued last year addresses the risk of “inadvertent custody,” the effect of standard letters of authorization, and first-party transfers. The author discusses the staff’s views on these subjects, suggests some appropriate procedures for advisers, and notes some open questions for which guidance is sought.

Keywords: “Inadvertent Custody”; Standing Letters of Authorization; First-Party Transfers

Affiliations:  1: Willkie Farr & Gallagher, LLP.

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