Webinar: Custody Rule: Compliance and Confusion

Wednesday, May 14, 2014
1:00 p.m. - 2:30 p.m. (ET)

Topics Covered

The custody rule presents significant challenges for investment advisers. In particular, the definition of custody applied to a variety of scenarios continues to be a source of confusion. SEC examination officials have identified the custody rule as a top priority and have noted that they have observed “widespread non-compliance” with the rule. To address these issues, the panelists will discuss:

• How to analyze whether advisers have custody in various situations;
• Special issues for privately offered securities in both funds and separate accounts;
• How to avoid common custody deficiencies; and
• Form ADV and disclosure issues related to custody.


• Mari-Anne Pisarri, Partner, Pickard & Djinis LLP
• David Vaughan, Partner, Dechert LLP
• Karen Barr, General Counsel, IAA (Moderator)

Register Today

Registration for the live event has closed, but the recording can still be purchased by selecting the "Registration" link on the left side of this page.

Live Recording Both
Members and Associate Members $125* $125 $200
Non-Members $200* $200 $375
*Per computer login


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

About the Presenters

Mari-Anne Pisarri is a partner with the Washington, D.C. firm of Pickard and Djinis LLP, specializing in regulatory issues pertaining to investment advisers, registered credit rating agencies and service providers to the securities industry. In this regard, she advises clients on federal and state securities laws, processes registrations, designs compliance programs and assists with both internal compliance reviews and SEC compliance examinations, advances clients’ interests before regulatory and policy making bodies, and represents regulated entities in disciplinary proceedings. Pisarri received her J.D., magna cum laude, from Cornell Law School. She is a member of the New York and District of Columbia Bars.
David A. Vaughan, is a partner at Dechert LLP. He focuses his practice on investment management, primarily private funds. Previously, he was the senior private fund policy adviser in the U.S. Securities and Exchange Commission’s Division of Investment Management in Washington, D.C. In that capacity, he advised on all aspects of legal and regulatory policy related to private funds. During that period, he played a leading role in advising on Title IV of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the rules implementing those provisions, the Volcker Rule, and the European Union Alternative Investment Fund Managers Directive. Vaughan received his B.A., cum laude, from Bowling Green State University, and his J.D., cum laude, from Georgetown University Law Center.
Karen L. Barr is General Counsel of the Investment Adviser Association, a not-for-profit association that exclusively represents the interests of investment advisers registered with the SEC. Prior to joining the IAA in 1997, Barr was in private practice at Wilmer, Cutler & Pickering (now WilmerHale), where she represented clients with respect to SEC investigations, securities class action litigation, internal corporate investigations, and regulatory matters. Barr received her B.A., magna cum laude, from the University of Pennsylvania and her law degree, cum laude, from the University of Michigan Law School. She is a frequent speaker on investment adviser law, regulation, and compliance.


Registration Cancellation or Substitution

For the live webinar, cancellations and substitutions must be received in writing no later than 5:00 p.m. (ET) Monday, May 12, 2014. There are no refunds for cancellations received after this date. Email your requests to