The SEC Adopts Amendments to the Custody Rules

Skadden, Arps, Slate, Meagher & Flom LLP

Anastasia T. Rockas Philip H. Harris

On December 16, 2009, the Securities and Exchange Commission (the “SEC”) voted to adopt rule amendments designed to strengthen controls over client assets held by registered investment advisers or their affiliates. On December 30, 2009, the SEC published the adopting release for these amendments along with an interpretive release providing guidance to auditors. These amendments modify the amendments previously proposed in May 2009 in response to approximately 1,300 comment letters. The new rule will become effective on March 12, 2010.

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