Tag: Custody
IAA Provides Input on Non-DVP Practices under Custody Rule
The IAA has weighed in on the Division of Investment Management staff’s initiative to gather information on investment adviser and custodial trading practices that are processed or settled on a...
May 18, 2021
Tags: Custody
The Chief Accountant of the SEC’s Division of Investment Management has issued a “Dear CFO Letter” to assist funds, advisers, and their independent public accountants “in addressing certain accounting, auditing,...
May 04, 2021
Tags: Custody, Derivatives, Mutual Funds, SEC Investment Management, Valuation
SEC No-Action Letter Allows Funds to Custody Loan Interests
The SEC’s Division of Investment Management has issued a no-action letter that allows registered funds to self-custody interests in term or delayed draw corporate loans that are originated, negotiated, and...
January 25, 2021
Tags: Custody, Investment Company Act, Mutual Funds, SEC Investment Management
Federal Agencies Issue Fall 2020 Regulatory Agendas; Custody Moves to Long-Term Agenda
Federal agencies recently released the fall 2020 update to their regulatory agendas. Each agency’s agenda is generally divided into four sections: (i) the pre-rule stage, which includes actions an agency...
December 21, 2020
Tags: AML, CFTC, Custody, SEC Investment Management
How the Characteristics of Digital Assets Affect Compliance with the Custody Rule
July 27 2020
July 27, 2020
Tags: Bitcoin, Columns, Custody, Digital Assets, Guest Column
Adviser Fined for Failure to Distribute Annual Audited Financial Statements
Adviser Fined for Failure to Distribute Annual Audited Financial Statements May 26, 2020 The SEC has settled charges with a New Jersey-based investment adviser for failing to timely distribute annual...
May 26, 2020
Tags: Custody, SEC Enforcement
Florida Adviser Sanctioned Over Performance Fees, Custody Rule Violations
The SEC fined a Florida-based investment adviser and its president $61,808.34 in connection with violations of the Advisers Act Custody Rule, Compliance Program Rule, and certain antifraud provisions. Between February...
October 02, 2020
Tags: Custody, Private Funds, SEC Enforcement
SEC IM Director Dalia Blass Reflects on Division’s Work
In a recent speech, the SEC’s Division of Investment Management Director Dalia Blass reflected on the Division’s hard work and accomplishments throughout the year. She praised her staff’s hard work...
November 17, 2020
Tags: Coronavirus, COVID-19, Custody, Dalia Blass, Proxy Voting, Registered Funds, SEC Investment Management
Fall 2019 Regulatory Agendas Released; SEC Moves Accredited Investor to Short-Term Agenda, Adds Form 13F Filer Threshold November 27, 2019 Federal agencies recently released the Fall update to their...
November 27, 2019
Tags: Advertising Rule, AML, CFTC, Custody, DOL, FinCEN, Regulatory Agendas
SEC Examination Office Issues Risk Alert on Multiple Branch Offices
The SEC’s Office of Compliance Inspections and Examinations (OCIE) has issued a Risk Alert regarding staff observations from examinations of investment advisers operating from multiple branch offices. The Risk Alert...
November 12, 2020
Tags: Advertising Rule, Branch Office Supervision, Code of Ethics, Custody
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