Ray Mosca

May 7, 2024 | sifma.org | Kevin Carroll |Kevin Ehrlich |Ray Mosca

In this post, we discuss why the SEC’s 2023 custody proposal has significant potential impacts on clients, advisers, and other market participants and why the historical record of legislative history and SEC precedent must be taken into account while the SEC continues to examine their approach to this proposal. Last year, the SEC proposed an overhaul of custody requirement for registered investment advisers. The proposal relies heavily on Dodd-Frank granting new authority to take action.