New SEC Custody Rules for Investment Advisers
Implementing Effective Compliance Policies and Procedures to Avoid SEC Penalties and Sanctions
Recording of a 90-minute CLE webinar/teleconference with Q&A
Conducted on Thursday, March 25, 2010
Recorded event now available
This CLE webinar will analyze the SEC’s new custody rules for investment advisers, discuss key compliance requirements, and provide best practices for developing effective compliance programs.
Description
The SEC recently issued sweeping amendments to the custody rules under the Investment Advisers Act intended to strengthen requirements for safekeeping of client assets. The new rules encourage the use of independent custodians and impose additional controls on registered investment advisers (RIAs).
Advisers must undergo an annual surprise examination by an independent public accountant to verify client assets. There are additional disclosure and recordkeeping requirements. The rules provide guidance on policies and procedures that advisers should adopt as part of their compliance programs.
The new rules are complex and have significant associated costs, especially to smaller adviser groups. Counsel for investment advisers must carefully consider these compliance issues in structuring advisory relationships and reviewing existing compliance programs.
Listen as our authoritative panel of financial services attorneys discusses the SEC’s new custody rules for investment advisers, how these rules affect compliance programs and what investment advisers need to do to achieve compliance.
Outline
- Overview of new custody rules
- Surprised examination
- Impact on smaller RIAs
- Impact on pooled investment vehicles
- Agreement with the accounting firm
- Delivery of account statement and notice
- Internal control report — SAS-70
- Related persons
- Fee-only RIAs
- Surprised examination
- Compliance policies and procedures
- Background checks for employees with access to accounts
- Checks and balances for movement of assets and account updates
- Checks and balances for employee access to assets
- Controls for employee who acquire custody of client accounts
- Segregation of duties of advisory personnel from custodial personnel
- Internal reporting requirements
- Books and records rule
- Amendments to SEC forms
III. SEC enforcement trends
Benefits
The panel will review these and other key questions:
- How has the surprise examination requirement been expanded?
- Are "fee-only RIAs" required to undergo a surprise examination?
- What is the role of the SAS-70 report?
- What is the impact of the new rules on pooled investment vehicles?
- What guidance does the SEC provide for compliance policies and procedures?
Faculty
Daphne Tippens Chisolm,
Partner
Law Offices of DT Chisolm, Charlotte, N.C.
She counsels small and large registered investment advisers to ensure compliance with the Investment Advisers Act. She has practiced securities law for more than 15 years, having worked in the private sector both before and after her tenure in the federal government. From 1999-2007, she worked for the SEC in the Division of Investment Management as senior counsel for the Office of Chief Counsel.
Fiona A. Philip,
Partner
Howrey, Washington, D.C.
She represents corporations and their officers, directors and employees in government proceedings before the SEC, DOJ, FINRA and other law enforcement agencies and regulatory bodies. She is a former Enforcement Counsel to the Chairman of the SEC, and former Senior Counsel in the Financial Fraud Task Force of the SEC Division of Enforcement.
Dilia M. Caballero,
Associate General Counsel
E*Trade Financial, Arlington, Va.
She is a member of the Brokerage Legal Department at E*TRADE FINANCIAL Corp. and provides advice regarding the Investment Advisers Act and Investment Company Act. Prior to joining E*TRADE, she was an attorney in the Financial Services Group at Dechert LLP from 1997-2006.
Ordering
Online CLE - Audio Recording
Includes audio streaming of full program plus handouts (available 24 hours after live seminar).
CLE:
Pre-approved for participatory or non-traditional/alternate format credit in: CA, HI*, NY*, WV*.
Pre-approved for self-study credit in: AK, AZ, MO, MT, TX*, VT, WA.
Upon request, also available in: CO, CT*, FL, GA, ID, KY, LA*, ME, NC, ND, NE, NH, NM, NV, OR*, SC, TN, UT, WI, WY. If you are applying for credit in one of these states, make sure to select those states when placing your order.
(*Indicates that Strafford must report attendance.)
Online CLE Audio $149.00
Available 24 hours after the live event
Recorded Event
Includes full event recording plus handouts (available after live seminar).
CLE: Pre-approved for self-study credit in: AK, AZ, CA, CT, HI, MO, MT, NY, TX*, VT, WA, WV. Upon request, self-study credit is also available in: CO, FL, GA, ID, KY, ME, ND, NE, NH, NM, NV, OR, UT, WI, WY. If you are applying for self-study credit in one of these states, contact Strafford CLE at 1-800-926-7926 ext. 35 or CLE@straffordpub.com. (*Indicates that Strafford needs to process the CLE — see below to purchase this option.)
Webinar Download (Slide Presentation with Audio) $49.00
Available three business days after the live event
DVD (Slide Presentation with Audio) $49.00
plus $9.45 S&H
Available ten business days after the live event
MP3 Download (Audio with Slide PDFs) $49.00
Available 24 hours after the live event
CD (Audio with Slide PDFs) $49.00
plus $9.45 S&H
Available ten business days after the live event
Webinar/Teleconference
Strafford webinars/teleconferences offer several options for participation: online viewing of speaker-controlled PowerPoint presentations with audio via computer speakers or via phone; or audio only via telephone (download speaker handouts prior to the program). Please note that our webinars do not feature videos of the presenters.
CLE Credit
Strafford's live seminars qualify for CLE in every state that accredits webinars. They offer you a high quality, cost effective, and convenient CLE option, with no lost travel time or expenses.
Customer Reviews
The webinar was very easy to use and I liked that the speakers were very knowledgeable.
E. Moses Vejil
Bingham Greenebaum Doll LLP
Very good and concise CLE.
Anthony DiSandro
Stevens & Lee
The teleconference contained information that was relevant, useful and up-to-date.
Mark Hegedus
Spiegel & McDiarmid
I found the content very useful and was impressed by the high quality of each speaker's ability to articulate his presentation.
Andrew Lillie
Hogan & Hartson
Very well-organized.
Kerin Coughlin
Constantine Cannon
Finance Law Advisory Board
Partner
Gibson Dunn & Crutcher
Partner
Nixon Peabody
Partner
Alston & Bird
Counsel
Mayer Brown
Partner
O’Melveny & Myers
Our Guarantee
Strafford webinars and teleconferences are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10.