Custody – Get It Right: Just in Time for Your Annual Updating Amendment!

The SEC’s Custody Rule and its application to registered investment advisers is complicated and often misunderstood, and custody issues remain among the most common deficiencies cited during SEC exams.

Download this important ComplianceCast to understand the key elements of the Custody Rule; identify available exceptions to certain requirements of the Custody Rule based on industry and SEC guidance; and learn how to identify accounts over which your firm has custody for purposes of Form ADV.

Covering topics and questions regarding:

  • SLOAs (must be included in response to Item 9 of Form ADV after 10/01/2017)
  • Third Party wires
  • Third Party checks
  • First person transfers
  • Client Custodian and IMA contracts
  • Documentation
  • and more

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