"There is no legal authority cited in the Commission Order for the finding that mutual fund share class selection implicates an investment adviser’s duty to ...
"The proposal requires, for the first time, that advisers and qualified custodians enter into written agreements with each other that help guarantee the custodian’s protections"
"My second set of concerns is around the proposed rule’s workability .... Getting custodians to enter into written agreements and provide the required reasonable assurances ...
"Today’s proposed amendments apply to all assets over which an investment adviser has custody. It does not favor or discourage one asset class over another"
"The proposing release takes great pains to paint a 'no-win' scenario for crypto assets"
"Today’s proposal represents another important step in the Commission’s efforts to modernize and strengthen the implementation of our federal securities laws. By expanding custody protections, ...
"Now, that’s not to say this change will be new; in fact, this change simply brings us back to the T+1 settlement cycle our markets ...
"But [I] do want to make one final plea to Chair Gensler. Why not adopt a September 3, 2024 compliance date? I will vote for ...
"While it is clear that T+0 will entail greater operational and technological challenges than the move to T+1, I agree with commenters that such a ...
"In my view, we are in an imprudent rush away from a sensible transition date and, for that reason, I am unable to support the ...