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ARTICLE · 18 DECEMBER 2009

Securities And Exchange Commission Votes To Amend The Custody Rule

O'Melveny & Myers LLP
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On December 16, 2009, the Securities and Exchange Commission (the "SEC") voted unanimously to amend Rule 206(4)-2 (the "Custody Rule") under the Investment Advisers Act of 1940, as amended.

United StatesStrategy
Chris Salter
Chris Salter
Peter Vaglio
Peter Vaglio

On December 16, 2009, the Securities and Exchange Commission (the "SEC") voted unanimously to amend Rule 206(4)-2 (the "Custody Rule") under the Investment Advisers Act of 1940, as amended. The amendments approved by the SEC are intended to address recently disclosed misappropriations of client assets by registered investment advisers and restore public confidence in the investment advisory industry and the SEC. We previously analyzed the SEC's proposed amendments to the Custody Rule in an O'Melveny & Myers Client Alert dated June 2, 2009 (Click to read "SEC Proposes Changes to the Custody Rule that Go Too Far; Impose Significant Costs and Fail to Address Shortcomings in the Existing Rule," a June 2009 O'Melveny Client Alert) (the "Proposed Amendments").

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