The SEC Division of Investment Management (the
"Division") extended no-action relief regarding
compliance by certain investment advisers with the
Investment Advisers Act Rule 206(4)-2 (the "Custody
Rule"). The no-action relief relates to the performance of
audits when an investment adviser is deemed to have custody by
virtue of keeping assets with a broker-dealer that is a related
Absent adoption by the Public Company Accounting Oversight Board
("PCAOB") of a permanent program for the inspection of
broker-dealer auditors, the position taken in the previous no-action letter would have
expired on December 31, 2016. The extended no-action relief
now expires the earlier of: (i) December 31, 2019; or
(ii) when the SEC approves a PCAOB-adopted permanent
The Division explained that it is extending this no-action
relief "[i]n light of the PCAOB's on-going Temporary
Rule and its continued work on presenting a rule proposal for a
permanent inspection program." The Division noted that
the PCAOB has indicated that it anticipates presenting
a corresponding rule proposal for a permanent inspection program in
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