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SEC Staff Provides No-Action Relief from Custody Rule for Principals-Only Funds
31 March 2015
View Client Update
The SEC staff has provided no-action relief from the audit and surprise examination requirements of the Custody Rule with respect to certain “principals-only funds.”
This relief is limited to funds whose investors are, among other things, executive officers of the manager who also have a material ownership stake in the manager, along with their spouses and minor children.
Given the restrictive definition of “principals,” the no-action relief will likely not apply to most employee or “friends-and-family” funds.
Kenneth J. Berman
Rebecca F. Silberstein
Gregory T. Larkin
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