On March 16, 2020, the Securities and Exchange Commission’s Division of Investment Management announced additional COVID-19 related relief. This relief is available on the SEC’s COVID-19 page, available here, and summarized below.
Operation of Business From Temporary Locations. The conduct of business from temporary locations, such as an employee’s home, as part of a firm’s business continuity plan due to circumstances related to COVID-19 does not require an update to either Item 1.F of Part 1A or Section 1.F of Schedule D. See full guidance here.
Inadvertent Custody. An adviser that is unable to access mail or deliveries at an office location due to the firm’s business continuity plan in response to COVID-19, would not be considered to have received client assets at that office location until firm personnel are able to access the mail or deliveries at that location. See full guidance here (See the second response to Question II.1).