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Category Archives: Custody

Form ADV Part 1 Custody Changes

As part of CRD/IARD Software Release 2010.4 (click here to access the release), the United States Securities and Exchange Commission (“SEC”) announced changes to the custody questions listed on Form ADV Part 1.  Specifically, the following changes have been made to Item 9 of Form ADV Part 1: SEC registered advisers must continue to indicate [...]

 
Posted by Bryan Hill
Monday, November 15, 2010
Labels: Custody, Form ADV, IAR Licensing, IARD

 

SEC Update FAQs of New Custody Rule

The Division of Investment Management of U.S. Securities and Exchange Commission (“SEC”) recently updated ”Staff Responses to Questions About the Custody Rule.”  (For a link to Staff Responses click here).  In the updated responses, the Division provided new guidance concerning a variety of issues related to the custody rule. Two important issues discussed by the SEC [...]

 
Posted by Bryan Hill
Thursday, June 3, 2010
Labels: Custody

 

Registered Investment Adviser to Celebrities Charged in Custody Fraud Case

Kenneth Starr, an investment adviser representative, to several celebrities and other wealthy clients, was arrested on May 27th for allegedly using client funds for his own personal use.  Starr has been charged in a New York District Court with fraud by an investment advisor, a wire fraud scheme to obtain property, money laundering, false statements in an [...]

 
Posted by Bryan Hill
Thursday, June 3, 2010
Labels: Criminal, Custody, Uncategorized

 

Is Your RIA Aware of the New Custody Rule’s Implications for Affiliated Intro B-Ds, Qualified Custodians and Pooled Investment Vehicles?

Does your SEC registered investment adviser or its affiliate serve as an introducing broker-dealer or qualified custodian for investment advisory accounts? If so, are you aware of the new internal control report requirements of the U.S. Securities and Exchange Commission (“SEC”)? Our webinar, Impact of New Custody Rule on an RIA Operating a B-D, Qualified [...]

 
Posted by Bryan Hill
Monday, March 29, 2010
Labels: Custody, Pooled Investment Vehicle, Webinar

 

Many Investment Advisers Are Not Prepared for SEC’s New Custody Rule

Although the recent changes by the U.S. Securities and Exchange Commission (“SEC”) to the custody rule for federally registered investment advisers went into effect on March 12, 2010, it appears that many investment advisers mistakenly assume they don’t have custody, misinterpret the definition of custody or believe they are somehow exempt from the custody rule [...]

 
Posted by Bryan Hill
Monday, March 29, 2010
Labels: Custody, Webinar

 

Is Your Investment Adviser Aware of the Custody Implications of Accepting Client Securities

Accepting third-party checks and securities for forwarding to a client’s qualified custodian seems to be a common practice at many investment advisory firms. Many investment advisers process the delivery of third-party checks and securities as a convenience to clients; however, it is important to understand the implication such processes have on the firm’s custody policies [...]

 
Posted by Bryan Hill
Friday, March 26, 2010
Labels: Custody

 

Is Your Pooled Investment Vehicle In Compliance with the SEC’s New Custody Rule for Investment Advisers

The recent changes by the U.S. Securities and Exchange Commission (“SEC”) to Rule 206(4)-2 under the Investment Advisers Act of 1940 include an important development for investment advisers that operate so called pooled investment vehicles. Pooled investment vehicle is an SEC term and includes private investments such as limited liability companies and limited partnerships not [...]

 
Posted by Bryan Hill
Sunday, March 21, 2010
Labels: Custody, Hedge Funds, Pooled Investment Vehicle, Webinar

 

Does the SEC’s new Internal Control Report Requirement Impact your Investment Adviser Firm or Introducing Broker/Dealer?

Internal Control Report Earlier this month, new requirements under SEC Rule 206(4)-2 of the Investment Advisers Act of 1940 went into effect. The most stringent (and expensive) of these requirements is the new internal control report rule. Investment advisers or their related persons that serve as qualified custodian for investment advisory client funds or securities [...]

 
Posted by Bryan Hill
Sunday, March 21, 2010
Labels: Custody, Webinar

 

SEC Offers Guidance to Investment Advisers for Co-Trustee Arrangements Under the New Custody Rule

Yesterday, the Division of Investment Management of the U.S. Securities and Exchange Commission (“SEC”) updated its Staff Responses to Questions About the Custody Rule. In the updated responses, the Division provided guidance for co-trustee arrangements. As a result of the new guidance, we have revised our Investment Adviser Compliance Alert published yesterday. For an updated [...]

 
Posted by Bryan Hill
Thursday, March 11, 2010
Labels: Custody

 

Our Complimentary White Paper About the SEC’s New Custody Rule for Investment Advisers Is Now Available

Due to overwhelming number of questions and apparent confusion among many federally registered investment advisers, we’ve prepared a complimentary white paper exploring the new custody rule of the United States Securities and Exchange Commission (“SEC”). This white paper provides details regarding the definition of custody, examples of custody and requirements under the new SEC rule. [...]

 
Posted by Bryan Hill
Thursday, March 11, 2010
Labels: Custody

 
  

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* RIA Compliance Consultants, Inc. ("RCC") is not a law firm and does not provide legal services. A compliance consulting relationship with RCC is not provided those legal and professional protections that normally exist under an attorney-client relationship. For more information, please visit our Disclosures webpage.

The determination to use a third-party compliance services provider is an important decision and should not be based solely upon advertisements or self-proclaimed expertise. A description or indication of limitation of our compliance services does not mean that an agency or board has certified RCC as a specialist or expert in investment advisor compliance. All potential clients are urged to make their own independent investigation and evaluation of RCC.

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