Course Description:
On February 23, 2023, the SEC proposed new rules and amendments to Rule 206(4)-2 (Safeguarding Rule). If adopted, the rule would expand the types of assets subject to the Safeguarding Rule, expand the definition of custody to include discretionary trading authority, require advisers to enter into specific agreements with qualified custodians and impose other substantial new custody, disclosure and recordkeeping requirements for investment advisers intended to protect clients. In the meantime, the SEC has been aggressively examining firms for compliance with the existing custody rules and initiated a series of enforcement actions for both substantive and technical noncompliance issues.
This session explores the various ways in which a firm may have custody (including first- and third-party transfers from client custodial accounts) and discuss best practices for designing procedures to prevent your firm from having “inadvertent custody.” Additionally, the session will highlight recent enforcement issues and their implications on investment advisers.
Learning Objectives:
- Identify practices in your firm that are potential sources of custody
- Analyze the very latest custody-related observations from the SEC
- Review recent custody-related enforcement actions
Speakers
Coming soon!
Who is this for?
For Whom: Designed to increase the professional competence of financial services compliance professionals with legal, compliance, operations, technology, administrative and management responsibilities.
Suggested Skill Level: Intermediate
Instructional Method: Group-Internet-Based
Pre-requisites for participation: No pre-requisites are required.
Advance Preparation: None
Continuing Education Credits
COMPLY Continuing Education Guide
Maximum Recommended CPE Credit: 2 in the Regulatory Ethics field of study
Maximum Recommended IACCP® CE Credit: 2
Maximum Recommended CA MCLE Credit: 2
