S4:E3 | Breaking Down The New SEC Custody Rule Proposal | Compliance In Context

Welcome back to the Compliance in Context Podcast! On today’s show, we take an in-depth look at the SEC’s new Custody rule proposal and the impact of these new requirements on investment advisers, broker-dealers, and custodians. In our Headlines section, we examine the new Cybersecurity rule proposal (also known as Rule 10) and the new proposed amendments to Reg S-P. And finally, we’ll wrap up today’s show with another installment of History Has Your Back, where in honor of Women’s History month, we look at a legendary Greek physician who helps show us how women have been breaking down barriers across the centuries.

Show

 Headlines

• SEC Proposes New Cybersecurity Requirements
• SEC Proposes Amendments to Reg S-P
• SEC Proposes Expanded Application of Reg SCI

Interview with Issa Hanna and Genna Garver

• History and background of the Custody Rule and recent developments
• What are the specifics of the rulemaking?
• Review of the scope of assets covered under the rule proposal
• How are real estate assets treated?
• What is the scope of activities covered?
• What is the impact on managers that have discretionary authority?
• Review of the written agreement and attestation requirements
• What is the real cost of compliance here?
• What does this rule tell us from a policy perspective about the focus of the SEC in this area?

History Has Your Back

• The legend of the Greek physician Agnodice
• Celebrating women in the investment management space

Quotes

17:20 – “I think one of the major things that they’re doing here as a part of this rule–or this rule proposal–is to bring the guidance that’s been scattered all over the place, within the text of the rule. So everyone knows where to find everything. It’s all accessible. That is something that everybody should welcome, right? Regulators should make the rules and make the guidance as accessible to everyone as possible.” – Issa Hanna

44:21 – “I just think that there is this misconception that the assets we’re talking about have to be the assets that they’re providing investment advice on. And it’s much broader than that, even under the current rule, so I think that’s something to look out for.” – Genna Garver