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The SEC's Division of Investment Management has issued a no-action letter concerning Investment Advisers Act Rule 206(4)-2 ("Custody of Funds or Securities of Clients by Investment Advisers"). The "Custody Rule" indirectly requires that auditors who perform certain functions for SEC-regulated entities be subject to regular inspection by the Public Company Accounting Oversight Board ("PCAOB"). According to the SEC letter, however, the PCAOB has yet to adopt a permanent program for such inspections. Therefore, the SEC previously issued a no-action letter stating that the SEC would not take