$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
Past Conference Speaker Inspiration for The Rock’s Next Blockbuster
If you attended Ascendant’s 2016 San Diego conference, you will no doubt remember our outstanding keynote speaker, Jeff Glasbrenner. Jeff is a below-the-knee amputee who was fresh off becoming the first American amputee ever to scale Mount Everest. In San Diego, he spoke about turning challenges into triumphs, and about succeeding in the face of … Continued
Relief at Last – New Guidance on Inadvertent Custody
The SEC quietly provided additional guidance to the industry about inadvertent custody in supplemental responses to the Custody Rule FAQs. In Question II.11 and II.12, the SEC stated that it would not recommend enforcement against an adviser that does not have a copy of a client’s custodial agreement, and does not know or have reason … Continued
Advisers Beware: FBI “Operation WireWire” Shows Firms Increasingly Being Targeted Using SEC Filings
Ascendant has observed more and more investment advisers falling victim to Business Email Compromise, or “BEC” schemes over the past year. Unfortunately, they are in good company, as the trend is consistent with a worldwide increase in such attacks by increasingly skilled hacker networks around the world. On June 10, 2018, the FBI announced in … Continued
Deputy Attorney General Rod Rosenstein Discusses Compliance Program Effectiveness
The embattled U.S. Deputy Attorney General Rod Rosenstein recently spoke to compliance pros at the 2018 Annual Conference for Compliance and Risk Professionals. Bulleted below are some of the statements from his keynote speech, which evidence the view from near the top of the Department of Justice: As to what it means to have a culture … Continued
Cayman Islands Update AML Regulations for Private Equity
The Cayman Islands has further bolstered its anti-money laundering (“AML”) and countering of terrorist financing (“CTF”) rules. The new AML/CTF rules become effective on May 31, 2018 and will affect, among others, unregulated investment entities—such as private equity firms—domiciled in the Cayman Islands. The deadline to appoint AML officers, however, is September 30, 2018 for … Continued
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