Tag: Custody
The issues include sustainable investing, proxy voting, modernization of the Custody and Pay-to-Play Rules, e-delivery, investor testing of Form CRS, appropriate regulation of smaller advisers, and effective coordination with other regulators.
May 19, 2021
Tags: Custody, Diversity & Inclusion, E-Delivery, Form CRS, Gary Gensler, Karen Barr, Pay-to-Play, Proxy, Reg BI, Sustainable Investing
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 non-delivery versus payment (non-DVP) basis.
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, financial reporting, or other related disclosure matters.”
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 structured by one or more primary lenders.
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
An update on the SEC’s, FinCEN’s, DOL’s, and CFTC’s regulatory agendas as they relate to investment advisers.
December 21, 2020
Tags: AML, CFTC, Custody, SEC Investment Management
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.
November 17, 2020
Tags: Coronavirus, COVID-19, Custody, Dalia Blass, Proxy Voting, Registered Funds, SEC Investment Management
SEC Examination Office Issues Risk Alert on Multiple Branch Offices
OCIE has issued a Risk Alert regarding staff observations from examinations of investment advisers operating from multiple branch offices.
November 12, 2020
Tags: Advertising Rule, Branch Office Supervision, Code of Ethics, Custody
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.
October 02, 2020
Tags: Custody, Private Funds, SEC Enforcement
How the Characteristics of Digital Assets Affect Compliance with the Custody Rule
When Satoshi Nakamoto published a white paper describing an “electronic peer-to-peer cash system” called Bitcoin to an obscure cryptography mailing list in 2008, the last thing on their mind was likely the U.S. federal securities laws.
July 27, 2020
Tags: Bitcoin, Columns, Custody, Digital Assets, Guest Column
Adviser Fined for Failure to Distribute Annual Audited Financial Statements
The SEC has settled charges with a New Jersey-based investment adviser in violation of the Custody Rule
May 26, 2020
Tags: Custody, SEC Enforcement
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