The Board of Directors of the North American Securities Administrators Association, Inc. (“NASAA”) has authorized release for internal and public comment the following proposed changes to Model Rules 102(e)(1)-1 and 203(a)-2 under the Uniform Securities Act of 1956 and Model Rules USA 2002 411(c)-1 and USA 2002 411(f)-(1) under the Uniform Securities Act of 2002 to clarify requirements relating to inadvertent custody of client funds.

Public Comment Period
The comment period will remain open to February 12, 2013.  To facilitate consideration of comments, please send comments to Greg Abram (, Chair of the Investment Adviser Section Regulatory Policy and Review Project Group, and Joseph Brady ( and A.Valerie Mirko (, NASAA Legal Department. We encourage, but do not require, comments to be submitted by e-mail.  Hard copy comments can be submitted at the address below. We also welcome any general comments on the model custody and recordkeeping rules.  

NASAA Legal Department
Joseph Brady, General Counsel
A.Valerie Mirko, Assistant General Counsel
750 First Street, NE, Suite 1140
Washington, DC  20002

Model Custody and Recordkeeping Rules (pdf)