Under Looming CAT Deadlines, Firms Try to Land on Their Feet

Despite the current global health and market difficulties, the Consolidated Audit Trail (CAT) is still a hot topic in the industry.  The SEC has provided Exemptive Relief through a No Action Letter until May 20, 2020, though the participants have requested additional relief.  This has impacted a few of our customers who have reacted to… READ MORE

Alert – SEC Issues Guidance Update on Inadvertent Custody

The SEC’s Division of Investment Management issued a February 2017 Guidance Update regarding situations where an adviser might inadvertently have custody. The key takeaway is that the definition of “custody” is to review agreements with qualified custodians to determine if they give an advisor the ability to withdraw or transfer client funds or securities.  If… READ MORE