This session will focus on the latest interpretations of the custody rule and how these apply to various situations within firms and across major custodians. The speakers will discuss the applicability and strategies for analysis and disclosure obligations, what they have learned, and what they would do differently. The session will include case studies or scenarios that discuss various applications of the custody rule.
• Explore the SEC Division of Examinations 2020 Multi-Branch Initiative’s custody-related findings and custody-related enforcement actions
• Discuss best practices, the use of standing letters of authorization and the effect of new products on complying with the SEC’s ever-evolving custody rule interpretations
• Examine the many forms of inadvertent custody and ways to remediate various situations
• Review the scope of the authorized trading exception to the Custody Rule