Ascendant’s ComplianceCast series returns on Friday, March 24 with a hot topic: recent SEC guidance on custody.
Last month, the Division of Investment Management issued a Guidance Update related to inadvertent custody of client funds or securities. The SEC also issued a long-awaited no-action letter that offered deeper clarity on the rule. ComplianceCast goes in depth on the topic, discussing all of the following:
This ComplianceCast will address the complex topic, tackling practical implications of what circumstances now will constitute custody. New coverage of the following:
- SLOAs (authority to transfer client money to a third party)
- First Person Transfers (authority to transfer money to the same client)
- Custodial Agreement Provisions with Advisory Clients (which impute advisers with custody)
- Avoid Inadvertent Custody with Written Consent
Analyzing Recent SEC Guidance:
- Investment Adviser Association No-Action Letter, February 21, 2017
- IM Guidance Update February 2017, “Inadvertent Custody: Advisory Contract versus Custodial Contract Authority.”
- FAQs, prior no-action letters
Next steps: Good-faith effort and timing; adapting policies and procedures, written consent and IMAs.
Bonus coverage of more industry questions.
The panelists for the webinar will be: Christopher Gilkerson, SVP & General Counsel, Charles Schwab & Co.; Laura L. Grossman, Assistant General Counsel, Investment Adviser Association; Robert E. Plaze, Partner, Stroock & Stroock & Lavan LLP; and Jacqueline Hallihan, Partner, Ascendant Compliance Management
To register for this ComplianceCast, click here and fill out the registration form.
Written by: Ascendant Compliance Management