SEC Staff Grants Custody Rule No-Action Relief to Investment Adviser Acting as Administrative Agent

SEC Staff Grants Custody Rule No-Action Relief to Investment Adviser Acting as Administrative Agent


By: Jessica Forbes, Stacey Song, Joanna D. Rosenberg

On December 20, 2018, the staff (the “Staff”) of the Securities and Exchange Commission (“SEC”) granted conditional no-action relief to Madison Capital Funding LLC (“Madison”), an investment adviser registered with the SEC, from certain requirements under Rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”) in connection with Madison's administrative agent services for its loan syndication business. This memorandum provides a summary of the relief granted.

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