The FAQs for Rule 206(4)-2, the “custody rule,” have been updated to offer further guidance for investment advisers. Amy Lynch, Founder and President, comments that the clarification provided by the SEC on “inadvertent custody” is helpful for firms having clients with their own custodial relationships. In this new FAQ, the SEC describes how, depending on the facts and circumstances, an investment adviser may not be in violation of the custody rule. Ms. Lynch also notes that the custody rule should continue to be a priority item for the SEC going forward. See InvestmentNews, “Even after SEC’s additional guidance, custody remains complicated rule for investment advisers“
