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)
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Abstract:
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.