In December 2009 the SEC adopted amendments to rule 206(4)-2, the custody rule under the Investment Advisers Act of 1940. The effective date of the amended rule is March 12, 2010.

The SEC also adopted amendments to Items 7 and 9 of Form ADV, Sections 7 and 9 of Schedule D to Form ADV, and Instructions to Form ADV-E. SEC-registered investment advisers must provide responses to the revised Form ADV in their first annual amendment after January 1, 2011. The IARD system has been upgraded to accept Form ADV-E, accountants performing surprise examinations must file Form ADV-E electronically through the IARD system.