Publication
Financial Services Litigation Bulletin-February 2010
The Securities and Exchange Commission ("SEC") has acted to strengthen controls over client assets held by registered investment advisers ("RIAs") or their affiliates. Specifically, on December 16, 2009, the SEC acted at an open meeting to adopt rule amendments to Rule 206(4)-2, commonly referred to as the Custody Rule, under the Investment Advisers Act of 1940 (the "Advisers Act") as well as related amendments to Form ADV Part 1 and Rule 204-2 with respect to recordkeeping. The amendments were motivated by a surge of SEC enforcement actions in 2009 against several RIA's and broker-dealers alleging fraudulent conduct, including misappropriation or other misuse of investor assets, many arising out of ponzi scheme activity.
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About Snell & Wilmer
Founded in 1938, Snell & Wilmer is a full-service business law firm with more than 500 attorneys practicing in 16 locations throughout the United States and in Mexico, including Los Angeles, Orange County and San Diego, California; Phoenix and Tucson, Arizona; Denver, Colorado; Washington, D.C.; Boise, Idaho; Las Vegas and Reno, Nevada; Albuquerque, New Mexico; Portland, Oregon; Dallas, Texas; Salt Lake City, Utah; Seattle, Washington; and Los Cabos, Mexico. The firm represents clients ranging from large, publicly traded corporations to small businesses, individuals and entrepreneurs. For more information, visit swlaw.com.
