Client Alert

SEC Modernizes Investment Adviser Custody Rule

October 01, 2003

Investment Management Practice Group

The Securities and Exchange Commission has adopted amendments to the custody rule for SEC registered investment advisers, SEC Rule 206(4)-2, in order to modernize the Rule. The SEC initially proposed amending the Rule in July 2002 as we reported in our Client Alert Dated July 2002. On September 11, 2003, the SEC adopted the amendments in generally the form proposed with some modifications to take into account comments received by the staff.