CCO Resource Center: Custody Policies and Procedures
Chief Compliance Officer Committee
Custody Policies and Procedures
In July 2021, I was asked by a member of the CCO Committee to collect members’ compliance policies and procedures relating to custody. Of particular interest to the member seeking these policies and procedures were those specific to Loans and Asset Backed securities. Based on the responses I received, it appears that most funds may not have detailed compliance policies and procedures governing their custody arrangements. Six members of the Committee shared their policies with me. The policies I received ranged in length from 2 to 8 pages. These policies are organized in our compilation from the shortest to the longest. A link to this compilation is below. Please note that we have made every effort to redact any identifying or proprietary information from these documents. We apologize in advance if we failed to completely redact such information. Please do not share this document with anyone outside of your member firm. As additional members of the Committee share with us any policies and procedures they have relating to custody, we will add them to this compilation.
The documentation provided by ICI that may be accessed by members of the CCO Committee is restricted to the member’s use only and not for distribution or reproduction. Documentation may be used internally at member organizations but may not be shared outside the organization.