United States: SEC Sends Second Message To Private-Fund Sponsors On Audit Obligations Under Custody Rule Through Enforcement Actions - Goodwin Procter LLP

On September 5, 2023, almost one year since its first flurry of similar Custody Rule actions, the SEC announced settlements with five SEC-registered investment advisers to private funds with respect to alleged violations of Rule 206(4)-2 under the Investment Advisers Act of 1940 (the Custody Rule) and related Form ADV violations.