Tag Archives: custody

Standing LOAs as Custody – additional information

The No-Action Letter discussed in yesterday’s blog contains seven conditions that, if met, would allow an adviser to escape the need for a surprise exam: 1. The client provides an instruction to the qualified custodian, in writing, that includes the … Continue reading

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Standing LOAs Cause Advisers to Have Custody

from Cipperman Compliance Services LLC The staff of the SEC’s Division of Investment Management, in a recent No-Action Letter, has opined that an adviser has regulatory custody of client assets where a client grants even limited authority to transfer assets … Continue reading

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Custody Rule Concerns

There has been a lot of discussion the last month or so about whether an advisor has custody, and therefore required to have an annual surprise custody audit. The SEC has in several exams stated that a custodian’s contract could … Continue reading

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