SEC Staff Identifies Several Paths to “Inadvertent Custody” Under the Advisers Act Custody Rule

Last week, the staff of the Securities and Exchange Commission (“SEC”) clarified its views on certain arrangements that can result in investment advisers having “custody” of client assets, as defined in rule 206(4)-2 (the “Custody Rule”) under the...
By: K&L Gates LLP

K&L Gates LLP