1/ Great to see the direct engagement from @HesterPeirce on yesterday’s Staff statement. Important also to remember that the “Custody Rule” is under the Investment Advisors Act and only applies directly to investment advisors holding assets on behalf of their customers. https://twitter.com/hesterpeirce/status/1325971456832966656
2/ That said, “qualified custodian” status under the Custody Rule is used by many others as the “gold standard” for custodians more generally, but these are private arrangements, not something that applies by law.
3/ Interpretations of the Custody Rule would not necessarily apply to related provisions like Section 17(f) of the Investment Company Act or the Customer Protection Rule (15c3-3), although all of these rules share similar principles and policies of customer protection.
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