Does your SEC registered investment adviser or its affiliate serve as an introducing broker-dealer or qualified custodian for investment advisory accounts? If so, are you aware of the new internal control report requirements of the U.S. Securities and Exchange Commission (“SEC”)?
Is Your Pooled Investment Vehicle In Compliance with the SEC’s New Custody Rule for Investment Advisers
March 21, 2010
The recent changes by the U.S. Securities and Exchange Commission (“SEC”) to Rule 206(4)-2 under the Investment Advisers Act of 1940 include an important development for investment advisers that operate so called pooled investment vehicles. Pooled investment vehicle is an SEC term and includes private investments such as limited liability companies and limited partnerships not registered as investment companies. For example, unregistered hedge funds fall under this category.