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ARTICLE · 06 JANUARY 2010

SEC Adopts Changes To Investment Advisers Act Custody Rule

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On December 30, 2009, the Securities and Exchange Commission (the "SEC") published its final rule changes to certain custody and recordkeeping requirements under the Investment Advisers Act of 1940, as amended (the "Advisers Act") and related forms (the "Amendments").

United StatesStrategy

Article by John A. Brunjes , Cheri L. Hoff and Genna N. Garver

On December 30, 2009, the Securities and Exchange Commission (the "SEC") published its final rule changes to certain custody and recordkeeping requirements under the Investment Advisers Act of 1940, as amended (the "Advisers Act") and related forms (the "Amendments"). The Amendments, which were modified in part from the proposal, are designed to provide additional safeguards when a registered investment adviser ("RIA") has access to client funds and/or securities. As approved by the SEC, the Amendments significantly impact the custody practices of many private investment funds and their managers by requiring, under certain circumstances, either an annual surprise exam or audit by an independent public accountant, an internal control report and a liquidation audit. The Amendments go into effect sixty days after publication in the Federal Register.

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