FASB’s Invitation to Comment – Agenda Consultation
SIFMA provided comments to the Financial Accounting Standards Board (FASB) on its Invitation to Comment - Agenda Consultation (the “ITC”).
Summary
SIFMA requests further interpretive guidance under Rule 206(4)-2, the Custody of Funds or Securities of Clients by Investment Advisers, under the Investments Advisers Act of 1940. Several questions are requested from the Securities and Exchange Commission (SEC), including topics of “transfers among accounts and pre-authorized transfers,” “reasonable belief of statement delivery,” and “imputation of custody for registered representatives.”
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