transfers among a client's custodial accounts SEC has stated in Question II.4 guidance about transferring assets between custodians SEC Staff Responses to Questions About the Custody Rule Custody Rule.” Q&A from the SEC SEC has stated in Question II.4 Custody FAQs Custody Rule.” SEC Staff Responses to Questions about the Custody Rule what it says this SEC FAQ Custody Rule.” guidance about transferring assets between custodians transfers among a client’s custodial accounts FAQ on the Custody Rule custody FAQs page Staff Responses to Questions About the Custody Rule staff responses guide SEC 2013 Custody Rule FAQs SEC staff guidance In a recent staff response Updated FAQ custody FAQs page Custody FAQs