New SEC Custody Rules for Investment Advisers
Implementing Effective Compliance Policies and Procedures to Avoid SEC Penalties and Sanctions
SEC amendments effective March 12; New FAQs released March 10
Recording of a 90-minute CLE webinar with Q&A
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.
- 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
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?
Daphne Tippens Chisolm
Law Offices of DT Chisolm
She counsels small and large registered investment advisers to ensure compliance with the Investment Advisers Act. She... | Read More
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.Close
Fiona A. Philip
She represents corporations and their officers, directors and employees in government proceedings before the SEC, DOJ,... | Read More
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.Close
Dilia M. Caballero
Associate General Counsel
She is a member of the Brokerage Legal Department at E*TRADE FINANCIAL Corp. and provides advice regarding the... | Read More
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.Close