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SEC Custody Rule ‘No-Action’

1 SEC Custody Rule No-Action Letter and Additional Guidance - Frequently Asked QuestionsOn February 21, 2017, the Securities and Exchange commission (SEC) released a no-action letter providing additional guidance on how the Custody Rule applies to third-party money movement authority. This guidance outlines a set of conditions that, when followed, allow RIAs to avoid the annual surprise examination requirement of the rule (aka no-action relief ). The letter also clarified that a standing letter of authorization (SLOA) granting third-party money movement authority is deemed Custody .

1 SEC Custody Rule ‘No-Action’ Letter and Additional Guidance - Frequently Asked Questions On February 21, 2017, the Securities and Exchange Commission (SEC)

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