Custody

(a) Definitions. For purposes of this section: (1) Eligible Foreign Custodian means an entity that is incorporated or organized under the laws of a country ...

(a) Definitions. For the purpose of this section: (1) The term customer shall mean any person from whom or on whose behalf a broker or ...

This adviser is charged with engaging in principal transactions without obtaining client consent and violations of the custody rule.

    LCH.Clearnet Limited and LCH.Clearnet LLC December 19, 2014 RESPONSE OF THE OFFICE OF CHIEF COUNSEL DIVISION OF INVESTMENT MANAGEMENT Our Ref. No. 20141218162 ...

    ICE Clear Credit LLC December 19, 2014 RESPONSE OF THE OFFICE OF CHIEF COUNSEL DIVISION OF INVESTMENT MANAGEMENT Our Ref. No. 201412181554 File ...

    Chicago Mercantile Exchange December 19, 2014 RESPONSE OF THE OFFICE OF CHIEF COUNSEL DIVISION OF INVESTMENT MANAGEMENT Our Ref. No. 201412181148 File No. ...

As the annual Form ADV amending season draws near, don’t forget that in addition to your clients and potential clients, you will have an equally ...

An administrative proceedings release last week by the SEC indicates that Christopher Kelly, the former CCO at Sands Brothers Asset Management ($64M in AUM) in ...

This SEC document request letter shows examiners wanted to see proof that the adviser knew its custodians were sending notice of custody account statements, among ...

You’ve no doubt struggled with the SEC’s complex custody rule but nothing like Sands Brothers Asset Management ($64M in AUM) in New York. Its troubles ...