Regulatory Monitor: SEC Update
By Joshua B. Deringer and Jay S. Fitton
Philadelphia partner Josh Deringer and senior attorney Jay Fitton authored an article in The Investment Lawyer titled, “Regulatory Monitor: SEC Update.” The article discussed the guidance issued by the SEC Division of Investment Management on Rule 206(4)-2 (the custody rule) of the Investment Advisors Act of 1940.
The guidance provided clarity regarding three situations where questions have arisen about whether an advisor has custody of client assets. It also highlights the complexity of the custody rules, and the need for advisers to pay close attention to their arrangements regarding client assets to determine if changes are required to remain in compliance.
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