On December 30, 2009, the US Securities and Exchange Commission (SEC) published its final rule amending certain custody requirements under the Investment Advisers Act of 1940, as amended (Advisers Act) for registered investment advisers (RIAs).1 The SEC indicated in the Adopting Release that the amendments were adopted to enhance the safekeeping of investor assets in the wake of several high-profile fraud cases against investment advisers and broker-dealers.