Gregory S. Rowland, Leor Landa, Michael S. Hong, Zachary J. Zweihorn and Sarah E. Kim

Davis Polk Discusses SEC’s Proposed Safeguarding Rule for Registered Advisers

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On February 15, 2023, the SEC proposed a sweeping new rule (Proposed Rule) which would replace current Rule 206(4)-2 (Custody Rule) under the Investment Advisers Act of 1940 (Advisers Act or Act). The Custody Rule was originally adopted in 1962 …