SEC Rule 204-2 – Global Relay Intelligence & Practice

SEC Rule 204-2

Requires investment advisers to make and keep true, accurate and current books and records relating to their investment advisory business.

Rule Overview

Jurisdiction: United States

Regulator: SEC

Topic: Recordkeeping

Overview

Latest News

Records to be kept include:

Rule 275.204-2(1)

Journal including records forming the basis of entries in any ledger

Rule 275.204-2(2)

General and auxiliary ledgers

Rule 275.204-2(3)

Memorandum of each order

Rule 275.204-2(4)

All check books, bank statements, etc.

Rule 275.204-2(7)

Originals of all written communications received and copies of all written communications sent relating to recommendations or advice, etc.

Latest News More on IAA 1940 Rule 204

Enforcement

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The fines totalled over $115m – with one firm dodging the bullet but still finding sympathy from two dissenting commissioners.

Alexander Barzacanos, Julie DiMauro4 min read
Fintech

Comms monitoring takes centre stage with global regulators

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If your firm is subject to one or multiple regimes, you should ensure your controls and approach are aligned with the relevant regulators’ expectations.

Eoghan Hartigan | Bovill Newgate, Damon Batten | Bovill, Sylvaine de Gantes | Bovill4 min read
Fintech

How to get a handle on managing electronic communications

September 12, 2023

Practical advice on how to approach complying with recordkeeping requirements and federal securities laws.

Ji Kim | SEC33 min read
Enforcement

SEC Risk Alert highlights new areas of focus in Marketing Rule exams

June 14, 2023

SEC's latest Risk Alert tells investment advisers about added areas of emphasis during Marketing Rule-focused exams.

Julie DiMauro3 min read