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Webinar - Understanding the New SEC Guidance on the Custody Rule: SLOAs, First-Person Transfers, and Inadvertent Custody

Thursday, March 30, 2017
2:00 – 3:15 p.m. (ET)

The SEC staff recently issued three pieces of guidance on the often vexing Custody Rule:

  • A no-action letter specifying conditions under which surprise exams are unnecessary when SLOAs are used for transfers to third parties;
  • Updated Custody Rule FAQ II.4 where a client grants an adviser the authority to move money between the client’s own accounts (first-person transfers); and
  • An SEC Division of Investment Management Guidance Update addressing provisions in a separate custodial agreement entered into between an advisory client and a qualified custodian that inadvertently impute advisers with custody they otherwise did not intend to have.

Topics Covered

In this webinar, you will learn:

  • Conditions when using standing letters of authorization (SLOAs) that make surprise exams unnecessary.
  • What information is expected to be included in a client’s authorization for first-person transfers.
  • The thinking behind the Guidance Update on inadvertent custody, including language regarding delivery versus payment.
  • Timing expectations.
  • Steps to start taking now.


  • Aaron T. Gilbride, Senior Counsel, Chief Counsel’s Office, Division of Investment Management, Securities and Exchange Commission
  • Christopher Gilkerson, Senior Vice President and General Counsel, Charles Schwab & Co., Inc.
  • Melissa R. Harke, Senior Special Counsel, Division of Investment Management, Securities and Exchange Commission
  • Laura L. Grossman, Assistant General Counsel, Investment Adviser Association, Moderator

Webinar Audio Platform

Audio for this webinar will only be broadcast through the internet via your computer speakers. Please visit the IAA's Webinar FAQ page or email if you have questions.


Click the "Register" button on this page.

Registration for the live webinar has closed. You may register still register for the recording.

IAA Members and IAA Associate Members: The live webinar and recorded webinar are complimentary. (Registrations made on or before March 29 at noon ET are automatically registered for both the live webinar and the recording.)

Non-Members: The live webinar is $250 (per computer logon). The recorded webinar is $250. The cost for both is $475.


For questions regarding this webinar, call (202) 293-4222 or email

About the Presenters

Aaron T. Gilbride is a Senior Counsel in the Chief Counsel’s Office within the Division of Investment Management at the Securities and Exchange Commission. The Chief Counsel’s Office is responsible for investment adviser and investment company oversight, including issuing no-action letters, orders for exemptive relief, and other guidance. Prior to joining the Commission, he worked as an associate in the investment management practice at Stradley Ronon Stevens & Young in Washington, D.C. Download to see image
Christopher Gilkerson is Senior Vice President and General Counsel at Charles Schwab & Co. in San Francisco. He is a 17 year veteran at Schwab and heads the Institutional and Retail Legal Group responsible for Advisor Services, retail investment advisory programs, branches and call centers, brokerage operations, international, and e-business, and retirement services. Prior to Schwab Christopher was Assistant General Counsel for Market Regulation at the U.S. Securities and Exchange Commission in Washington, D.C., and an adjunct faculty member at American University, Washington College of Law. He has written and spoken on a wide range of securities industry topics. Download to see image
Melissa R. Harke is Senior Special Counsel in the SEC’s Investment Adviser Regulation Office in the Division of Investment Management. Her office is responsible for investment adviser oversight, including rulemaking, interpretive guidance, and general policy-related issues. Since joining the SEC in 2008 she has been heavily involved with the adoption and implementation of: amendments to the Advisers Act custody rule; amendments to investment adviser registration and reporting rules, including Form ADV; and the Advisers Act pay to play rule. Prior to joining the SEC, Melissa was an Associate in the Investment Management Group of the Washington, D.C. office of K&L Gates. Previously she was an Associate with Richards, Layton & Finger in the state of Delaware, and she was a law clerk in the Office of Hearing Officers at the NASD (now known as FINRA). Download to see image
Laura L. Grossman is Assistant General Counsel of the Investment Adviser Association. Prior to joining the IAA, Ms. Grossman was in private practice for over 10 years in the New York office of Fulbright & Jaworski L.L.P. (now Norton Rose Fulbright), where she advised registered investment adviser, mutual fund and private fund clients on matters arising under the Investment Advisers Act, the Investment Company Act and other federal securities laws, the Commodity Exchange Act and associated regulations, and a wide range of compliance issues. Download to see image

Paid Registration Cancellation or Substitution

For paid registrations, cancellations and substitutions must be received in writing no later than noon (ET) Wednesday, March 29, 2017. There are no refunds for cancellations received after this date. Email your requests to

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