$550
The complexity of the SEC’s Custody Rule is not to be underestimated. Custody issues remain among the most common deficiencies cited during SEC exams, and even firms with strong compliance programs have had challenges interpreting and applying the different rule elements, No-Action letters, FAQs and Investment Management Guidance Updates. Based on our experience in the field, Ascendant has created a unique offering to help you better understand the Custody Rule and how it applies to your business – the Ascendant Custody Toolkit.
Our Ascendant Custody Toolkit will help you understand and document compliance with the key elements of the Custody Rule; identify accounts over which your firm has custody; identify available exceptions to certain requirements of the Rule based on industry guidance; manage a list of accounts to provide to an accountant for a surprise examination; and evidence your analysis for determining the information in Item 9 of your Form ADV Annual Updating.
The Toolkit includes:
- A robust, interactive Custody Questionnaire
- A Form ADV Worksheet template
- Aggregated library with links and references to underlying regulatory material
- And more
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Latest Content
Coming to America – California Adopts GDPR-Like Privacy Regulation
After a number of firms struggled last year to get their marketing and information systems into compliance with the EU’s General Data Protection Regulation (GDPR), advisers to U.S. clients will soon be facing similar requirements on the home front. On the heels of the Cambridge Analytica scandal, California enacted the California Consumer Privacy Act of … Continued
SEC and FINRA 2019 Examination Priorities
The SEC and FINRA have recently released their examination priorities for 2019. These releases provide insight into regulatory priorities and serve as guidance for a firm in evaluating its compliance program. We will discuss topics covered in these releases, including: Protecting retail investors Fees and expenses Disclosure Conflicts of interest Suitability Protecting senior investors Trading … Continued
SEC Reopened After 35-Day Government Shutdown
SEC Chairman Jay Clayton announced on Saturday, January 26 that with an agreement reached to end the government shutdown, the “Commission has resumed normal staffing levels and is returning to normal operations.” In total, about 94% of the commission’s approximately 4,400 employees had been furloughed during the 35-day shutdown, according to its operations plan. In a … Continued
FINRA Rolls Out New Central Registration Depository Functionality; Annual Verification Deadline Nears
FINRA first introduced enhancements to the Central Registration Depository (“CRD”) on October 1, 2018, which were rolled out in support of FINRA’s restructured qualification examination program as well as the adoption of consolidated FINRA registration rules. The new enhancements were intended to also more easily assist member firms with satisfying their reporting and compliance obligations. … Continued
SEC’s Latest Risk Alert Focuses on Electronic Communications
The SEC’s most recent risk alert, “Observations from Investment Adviser Examinations Relating to Electronic Messaging,” issued on December 14, 2019, focuses on the use and maintenance of electronic communications for business purposes. The purpose of the alert is to remind advisers of their obligations related to personal use of electronic messaging and the requirements for … Continued
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