As we have previously discussed, in February 2017 the SEC’s Division of Investment Management staff took the position that registered investment advisers that trade loans and other assets on behalf of separately managed accounts that do not settle “delivery versus payment” (“DVP”), have “custody” of client assets under the Investment Advisers Act (the “Act”) and therefore must comply with the requirements of the custody rule, including the implementation of annual surprise audits.
This week we cover Regs, Analysts & Loans; February’s Secondary; Solving SOFR
Become a Member
Membership in the LSTA offers numerous benefits and opportunities. Chief among them is the opportunity to participate in the decision making process that ultimately establishes loan market standards, develops market practices, and influences the market’s direction.