February 9, 2010
Summary/Background
The Securities and Exchange Commission (“SEC”) recently adopted amendments to Rules 206(4)-2 (the “Rule”) and 204-2 of the Investment Advisers Act of 1940 (the “Amendments”), and Forms ADV and ADV-E. The Amendments are designed to strengthen controls on SEC-registered investment advisers with custody of client assets and deter fraudulent conduct and increase the likelihood of early detection of such conduct. Except as noted in this alert, an adviser must comply with the Amendments commencing March 12, 2010. To view a complete summary of the changes, please click here. To view the final SEC release, see http://www.sec.gov/rules/final/2009/ia-2968.pdf.