On March 5, the Securities and Exchange Commission updated its list of frequently asked questions and answers (FAQs) regarding Rule 206(4)-2, the custody rule under the Investment Advisers Act of 1940. The updates are in response to questions arising as a result of the SEC’s adoption of recent amendments to the custody rule. (For a summary of the custody rule amendments, click here.) The FAQs have been updated to reflect guidance on the following topics: compliance dates, definition of custody and scope of the rule, account statements and surprise exams, pooled investment vehicles, privately offered securities, auditing non-pool accounts and trustees.
The full text of the FAQs may be found here.