Abstract
This paper focuses on prominent issues surrounding the Custody Rule (Rule 206(4)-2) of the Investment Advisers Act of 1940. The Custody Rule has recently raised several issues for Securities and Exchange Commission (SEC)- registered investment advisers as they try to navigate through new markets and new industry practices. As such, this paper addresses the SEC’s recent guidance regarding custody with respect to standing letters of authorisation, asset transfers between client accounts, inadvertent custody, access to client log-in information, trustee relationships, the COVID-19 pandemic and non-delivery versus payment (DVP) transfer arrangements.
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