SEC IM letter provides guidance on custody, other issues

"We are expressing a Staff position that an investment adviser relying on the exception for limited partnerships (or limited liability companies or other types of pooled investment vehicles) that are subject to an annual audit in accordance with Rule 206(4)-2(b)(4) under the Investment Advisers Act of 1940 (the “Rule”) may, in certain circumstances, satisfy the requirements of the exception by distributing combined audited financial statements"